Ledger Privacy Policy

• When we decide how and why information is used, for example to run your account, bill you, give support, keep the service secure and meet our legal duties, Ledger is responsible for that information (the "controller").
• When your business enters information about its own customers, suppliers and staff into Ledger, your business is responsible for that information. We only process it on your instructions to provide the service (we are the "processor"). Our Terms and Conditions explain this in more detail.
• When you register an invoice, the Ministry of Revenues receives the invoice data and uses it under its own legal powers.

• Account and contact details: name, work email, phone number, job title, business name and address, and the users and permissions in your account.
• Business and tax details: TIN, VAT registration, branch details, system numbers and the credentials needed to connect to the Ministry's system.
• Business records you enter: invoices, receipts, credit and debit notes, customer and supplier details, products, prices, taxes, payments and attachments.
• Technical information: IP address, browser and device type, login and security events, dates and times, error logs and the responses received from the Ministry's system.
• Support information: your messages, call notes or recordings, attachments and contact history.
• Billing information: your plan, invoices, payment references and tax records. Payment providers may collect payment details under their own policies.

We do not need health information, biometric data or identity documents. Please do not send them unless we ask for them for a specific legal reason. Never send passwords or private keys by email, Telegram or support messages.

• From you, when you contact us, book a demo, register, use the platform, ask for help or pay.
• From your account administrator, who can create users and add staff or advisers.
• From the Ministry of Revenues' system, which returns invoice numbers (IRN), QR codes and status responses.
• From our website, through cookies and similar technologies (see section 9).
• From public business sources or referrals. In that case we will tell you where we got your details.

• To create and manage your account and to check that you are authorised to act for your business.
• To provide the service: issue invoices, register them with the Ministry, calculate VAT and produce reports.
• To give support and fix problems.
• To bill you and keep our own accounting and tax records.
• To keep the service secure and prevent misuse or fraud.
• To meet our legal obligations.
• To send you news about Ledger, only where the law allows it or you have agreed.

Depending on the purpose, we rely on our contract with you, our legal obligations, our legitimate interest in running a secure service, or your consent. Where we rely on your consent, you can withdraw it at any time.

When you issue an invoice, Ledger sends the information the law requires to the Ministry of Revenues' system: your TIN and branch details, the buyer's details where required, and the items, amounts and taxes. The Ministry returns an official number and a QR code, which we show on the invoice.

Once an invoice is registered, it is an official tax record. Closing your Ledger account, or asking us to delete your data, does not cancel it. To correct a registered invoice, use a credit note, a debit note or the official cancellation process.

We do not sell personal information or your business records. We share information only when it is needed:

• With your account administrator and the users you authorise, according to their permissions.
• With the Ministry of Revenues, when you register invoices.
• With our service providers (section 8), who work for us under contract and only for the purposes we set.
• With professional advisers, such as lawyers and auditors, who must keep it confidential.
• With courts or authorities, when the law requires it.
• With a buyer or successor if Ledger is sold or merged, with the same protections. We will tell you if this happens.

We will not use your name, logo or testimonial without your permission, and we will not use your business records to train general AI models.

Your account and business records are hosted in Ethiopia. This follows Article 22 of the Personal Data Protection Proclamation No. 1321/2024, which requires personal data collected in Ethiopia to be stored on a server or data centre in Ethiopia.

Two services we use for support and communication may process information outside Ethiopia:

• Telegram, for support chat.
• Zoho, for our support system and email.

Through these services we send only what is needed to answer you, and we apply the safeguards the Proclamation requires. Please do not send invoices, credentials or other sensitive records through these channels unless we ask for them.

Our main providers today are:

• Telecloud and Alet Cloud: cloud hosting and infrastructure in Ethiopia.
• AfroMessage: SMS, from Ethiopia.
• Safaricom: telecommunications.
• Zoho: support system and email.
• Telegram: support chat.

We may add or change providers. You can ask for the current list at info@ledger.et.

Our public website uses cookies and similar technologies:

• Essential cookies: needed for login, security and language. They are always on.
• Preference cookies: remember your choices.
• Analytics cookies: show us how visitors use the website so we can improve it.
• Advertising cookies and pixels, including the Meta Pixel: measure our adverts and show you relevant adverts on other websites. They may send your IP address, browser details and the pages you visit to the advertising provider, which may process them outside Ethiopia.

On your first visit, a cookie banner lets you accept or reject non-essential cookies. You can change your choice at any time from the link at the bottom of the website. Rejecting them does not stop you using the website.

Advertising and analytics tools are never used inside the Ledger platform. We never send TINs, invoice data, buyer details or support messages to advertising platforms.

We send service messages, such as security alerts, billing reminders and notices of important changes. These are part of the service.

We send promotional messages only where the law allows it or you have agreed. Every promotional email has a way to unsubscribe, or you can write to info@ledger.et. We never use the customer lists you upload to Ledger for our own marketing.

We may record support calls to check quality, resolve disagreements and train our team. We will tell you at the start of the call. If you do not want the call recorded, tell us and we will help you another way, for example by email.

When our team needs to access your account to solve a problem, access is limited to that problem and is logged.

We keep information only as long as it is needed and as long as Ethiopian law requires:

• Tax and invoice records: for the period the law requires, which is at least five years after the related tax declaration, or longer where the Commercial Code requires it.
• Account and business records: while your subscription is active. After it ends, your administrator can export the data for 30 days, and we delete it within 60 days, except what the law requires us to keep.
• Support messages, call recordings and security logs: only as long as they are needed for their purpose.
• Marketing preferences: we keep a short record of opt-outs so that we do not contact you again.

Backups are deleted automatically on a rolling cycle. Information deleted from the service disappears from the backups when that cycle ends.

We use technical and organisational measures to protect your information, including access control, separation of each customer's data, encryption where appropriate, secure handling of credentials, monitoring and backups.

No online service is completely free of risk. Protect your devices and passwords, give users only the access they need, and tell us at once at info@ledger.et if you suspect a problem.

If a security incident affects personal information, we will act quickly to contain it, inform affected customers without delay and notify the authority when the law requires.

Under Ethiopian law you may have the right to:

• know what information we hold about you and get a copy;
• correct inaccurate information;
• ask us to delete it or limit how we use it;
• object to certain uses, including direct marketing;
• withdraw your consent at any time;
• receive your information in a format you can use.

To use these rights, write to info@ledger.et. We may ask you to confirm your identity. We will reply within 30 days, or sooner if the law requires, and we will explain if a legal reason stops us from doing what you ask. Requests are free of charge.

If your information is in another business's records, for example because you are one of their customers, contact that business first. We will help them to answer you.

A registered invoice cannot be changed through a privacy request. It is corrected with a credit note or a debit note.

Ledger automatically calculates taxes, checks invoice data and runs security checks. These processes do not make decisions about you that have legal effects. We may use anonymous statistics, which cannot identify you or your business, to improve Ledger.

Ledger is a service for businesses. It is not intended for children.

If you have a concern, please contact us first at info@ledger.et so that we can solve it. You also have the right to complain to the Ethiopian Communications Authority (www.eca.et), which supervises data protection in Ethiopia.

We may update this policy. Each version shows its date, and we will tell you about important changes by email or in the platform before they apply.

This policy is available in English and Amharic. If the two versions differ, the English version applies.