Last updated: March 5, 2026
1. Introduction
SANC AG (“we,” “our,” or “us”) operates the LumaBill platform (the “Service”), a Swiss invoicing, bookkeeping, and business management solution. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Service. We are committed to protecting your privacy and ensuring compliance with the Swiss Federal Data Protection Act (nDSG) and the General Data Protection Regulation (GDPR).
3. Information We Collect
3.1 Information You Provide
- Guest Users: If you use our Service without an account, your invoice data (client details, items, amounts) is processed locally in your browser. It is not transmitted to or stored on our servers.
- Registered Users: When you create an account, we collect your email address and authentication credentials (managed via AWS Cognito). When you save invoices, client records, or profile settings, this data is transmitted via encryption (HTTPS) and stored securely in our database.
- Bookkeeping Data: If you use our bookkeeping features, we store your financial records including expenses, journal entries, chart of accounts, fiscal year data, vendor information, and bank account details.
- Bank Statements: If you import bank statements (CAMT.053/CAMT.054 or CSV files), we process and store the transaction data contained therein, including transaction amounts, dates, references, and counterparty information.
- Uploaded Files: If you upload files such as company logos, expense receipts, or other documents, these files are stored in our secure cloud storage (AWS S3).
- Payment Information: Subscription payments are processed by Stripe. We do not store your credit card details. Stripe processes and stores your payment information in accordance with PCI-DSS standards. We receive only a payment confirmation and a truncated card reference from Stripe.
3.2 Automatically Collected Information
We use Google Analytics to collect anonymized information about how you interact with our Service to improve user experience. We use cookies to manage user sessions, language preferences, and authentication state.
4. AI-Powered Features and Data Processing
LumaBill offers optional AI-powered features as a paid add-on. AI features are entirely opt-in — they are never activated unless you explicitly subscribe to the AI module and initiate an AI action. The following applies only if you choose to use AI features:
- Receipt Scanning: When you use AI receipt scanning, images of your receipts are sent to our AI processing infrastructure to extract vendor names, amounts, dates, and line items.
- Expense Categorization: When you request AI categorization, your expense descriptions and amounts are processed to suggest appropriate bookkeeping accounts.
- Bank Transaction Matching: When you use AI-assisted reconciliation, your unmatched bank transactions and existing expense records are analyzed to suggest matches.
AI Infrastructure: AI processing is performed via Amazon Web Services (AWS) Bedrock using the Swiss (Zurich) inference profile. Your data is processed within Switzerland and is not used to train AI models. Data sent to AI models is processed in real-time and not retained by the AI provider beyond the duration of the request.
Human Review: AI suggestions (e.g., expense categories, transaction matches) are always presented as proposals. You retain full control and must confirm or reject every AI suggestion before it is applied.
5. How We Use Your Information
We use the information we collect to:
- Provide, maintain, and improve the Service, including invoicing, bookkeeping, and reporting features
- Process your financial data for bookkeeping purposes as instructed by you
- Provide AI-powered features where you have opted in
- Process subscription payments and manage your account
- Send you transactional notifications (e.g., invoice delivery confirmations, subscription updates)
- Comply with legal obligations, including financial record retention requirements
6. Data Sharing and Disclosure
We do not sell your personal information. We share data with trusted third-party service providers solely for the purposes described above:
- Amazon Web Services (AWS): For hosting, database, authentication, file storage, email delivery (SES), and AI processing (Bedrock). Infrastructure located in Zurich, Switzerland.
- Stripe: For payment processing. Stripe acts as an independent data controller for payment data. See Stripe's Privacy Policy.
- Google Analytics: For anonymized analysis of website traffic and usage patterns.
We may also disclose your information if required by law, in response to a valid legal process, or to protect our rights and the safety of our users.
7. International Data Transfers
Our primary infrastructure, databases, and AI processing are located in Switzerland (AWS Zurich region). Your data never leaves Switzerland. Stripe may process payment data in other jurisdictions in compliance with applicable data protection standards, including appropriate safeguards under GDPR.
8. Data Retention
We retain your data as follows:
- Active accounts: All data is retained for as long as your account is active.
- Accounting records: In accordance with Swiss commercial law (OR Art. 958f) and the Ordinance on Commercial Bookkeeping (GeBüV), financial records including journal entries, invoices, expenses, receipts, and financial reports are retained for 10 years from the end of the fiscal year to which they relate. This obligation applies regardless of account status.
- Cancelled subscriptions: When you cancel your subscription, your account enters a read-only archived state. All data remains accessible for viewing and export.
- Account deletion requests: Non-accounting personal data (profile details, preferences, email settings) is deleted promptly. Accounting records subject to the 10-year retention obligation are retained in anonymized form until the retention period expires.
- Backups: Database backups containing your data may persist in encrypted, archived form for up to 30 days after deletion from the live system.
9. Data Security
We implement appropriate technical and organizational measures to protect your data, including encryption in transit (TLS/HTTPS), encryption at rest for stored data, access controls, and regular security reviews. However, no method of electronic transmission or storage is 100% secure, and we cannot guarantee absolute security.
10. Your Rights
Under Swiss and EU data protection laws, you have the right to:
- Access your personal data
- Correct inaccurate data
- Export your data in a portable format
- Delete your account and all associated data (via the “Delete Account” button in Settings)
- Object to or restrict certain processing activities
- Withdraw consent for optional processing (e.g., AI features) at any time by canceling the relevant add-on
You may also lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC) or the relevant supervisory authority in your jurisdiction.
11. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify registered users of material changes via email or in-app notification. Continued use of the Service after changes constitutes acceptance of the revised policy.
12. Contact Us
If you have any questions about this Privacy Policy or wish to exercise your data protection rights, please contact us at: support@lumabill.ch