Privacy Statement

Last updated: February 2025

This privacy statement explains what personal data myTransferPricing collects, why we collect it, how we protect it, and what rights you have. We aim to be transparent and straightforward.


1. Who We Are

myTransferPricing is an enterprise SaaS platform that helps multinational companies and advisory firms manage their transfer pricing documentation.


2. What Data We Collect

2.1 Account Information

When your organization administrator creates your account, we collect:

  • Identity data: First name, last name, email address
  • Contact data: Phone number, phone country code (optional)
  • Profile data: Avatar image (optional), timezone, currency, country, and date format preferences
  • Credentials: Password (hashed and managed by our authentication provider — we never store plaintext passwords)

2.2 Organization & Billing Information

Organization administrators provide:

  • Organization profile: Legal name, address, postal code, state/province, country
  • Billing contact: Billing name, billing address, billing email, contact person details, purchase order number
  • Subscription details: Selected plan, user/client limits, feature entitlements

We do not collect or store credit card numbers, bank account details, or payment card data. Payment processing is handled externally.

2.3 Client & Project Data

Users create and manage business data within the platform:

  • Client records: Client name, client code, industry classification, country, address, contact information
  • Fiscal year data: Year, date ranges, status
  • Transfer pricing projects: Project names, document templates, generated documents, variable values used in document generation
  • Files: Uploaded document templates (Word, Excel, PDF) and generated output documents, stored in cloud storage with version history

This is your organization's business data. We process it solely to provide the service — we do not use it for any other purpose.

2.4 Security & Authentication Data

To protect your account and detect unauthorized access, we collect:

  • Login events: Timestamp, authentication method (password, OTP, magic link, 2FA), success/failure status
  • IP addresses: Captured during login, OTP requests, magic link requests, and security-relevant actions
  • User agent strings: Browser and device information captured during authentication and audited actions
  • Two-factor authentication: Whether 2FA is enabled on your account (TOTP secrets are managed by our authentication provider)
  • Failed login tracking: Number of failed attempts (used to trigger temporary account lockouts for your protection)
  • OTP codes: One-time passwords generated for login verification (automatically expire after 10 minutes)
  • Magic link tokens: Stored as cryptographic hashes (not plaintext), with expiration timestamps

2.5 Audit Trail Data

All significant actions on the platform are logged for security and compliance:

  • What is logged: The action performed, which record was affected, who performed it, when it happened, from which IP address, and with which browser/device
  • Change tracking: For updates, we store the before and after values of changed fields
  • Automatic redaction: Sensitive values (passwords, tokens, API keys, secrets) are automatically replaced with [REDACTED] before being stored

2.6 Cookies & Session Data

We use a minimal set of cookies — all essential for the platform to function:

CookiePurposeTypeDuration
Session cookieMaintains your authenticated sessionEssential, HttpOnlySession
CSRF tokenProtects against cross-site request forgeryEssential, HttpOnly, Secure24 hours
Auth sessionAuthentication tokenEssential, HttpOnlyManaged by provider

We do not use advertising cookies, marketing trackers, or social media cookies.

2.7 Analytics Data

We use Vercel Analytics and Vercel Web Vitals to understand platform performance (page load times, error rates). This data is aggregated and not linked to individual user accounts.


3. Why We Collect This Data (Legal Basis)

PurposeData usedLegal basis
Provide the serviceAccount info, organization data, client/project data, filesPerformance of contract
Authenticate usersCredentials, OTP codes, 2FA data, session tokensPerformance of contract
Protect securityIP addresses, login events, failed attempts, user agentsLegitimate interest (security)
Maintain audit trailAll audited actions, IP addresses, change historyLegitimate interest (compliance)
Send transactional emailsEmail address, name, OTP codes, temporary passwordsPerformance of contract
Enforce rate limitsIP addresses, request countsLegitimate interest (stability)
Billing administrationOrganization billing details, contact informationPerformance of contract

4. Who We Share Data With

We share your data only with service providers that are necessary to operate the platform:

ProviderPurposeData shared
SupabaseDatabase, authentication, file storageApplication data, user credentials (hashed), uploaded files
ResendTransactional emailsEmail addresses, user names, OTP codes, organization names
VercelApplication hosting, cachingRequest data, CSRF tokens, rate limit counters
UpstashRate limit enforcementIP addresses, request metadata

We do not sell your data. We do not share data with advertisers. We do not use your data for AI/ML model training.


5. Where Your Data Is Stored

  • Application hosting: Vercel (globally distributed CDN with primary processing in the United States)
  • Database & file storage: Supabase (region depends on project configuration — typically US or EU)
  • Cache & rate limiting: Vercel KV / Redis (region configured to match deployment)
  • Email delivery: Resend (United States)

For users in the European Economic Area (EEA): Some of your data may be transferred to and processed in the United States. These transfers are protected by Standard Contractual Clauses (SCCs) and the data processing agreements of our service providers.


6. How We Protect Your Data

Technical Measures

  • Encryption in transit: All connections use HTTPS/TLS. HTTP Strict Transport Security (HSTS) is enforced.
  • Encryption at rest: Database encryption provided by Supabase. Sensitive fields redacted in audit logs.
  • Authentication security: Passwords hashed (bcrypt). Magic link tokens stored as SHA-256 hashes. OTP codes expire after 10 minutes.
  • Account protection: Automatic account lockout after repeated failed login attempts. Optional two-factor authentication (TOTP). Organization-level MFA enforcement.
  • Access control: Row Level Security (RLS) on all database tables ensures strict organization-based data isolation. Role-based access control (RBAC) with granular permissions.
  • Input validation: All user input validated with schemas at API boundaries.
  • Rate limiting: Redis-backed rate limiting on all endpoints to prevent abuse.
  • CSRF protection: Double-submit cookie pattern with constant-time comparison.

Security Headers

We enforce the following HTTP security headers on all responses:

  • Strict-Transport-Security (HSTS with preload)
  • X-Frame-Options: DENY (prevents clickjacking)
  • X-Content-Type-Options: nosniff
  • Content-Security-Policy (restricts script sources, prevents injection)
  • Permissions-Policy (disables camera, microphone, geolocation)
  • Referrer-Policy: origin-when-cross-origin

Organizational Measures

  • Multi-tenant architecture with strict organization-level data isolation
  • Comprehensive audit logging of all data access and modifications
  • Automatic redaction of sensitive data in logs
  • Principle of least privilege in role-based access

7. How Long We Keep Your Data

Data typeRetention period
Active account dataAs long as the account is active
Deactivated user accountsSoft-deleted (marked inactive); recoverable by organization admin
Audit logsRetained indefinitely for compliance; periodically archived
OTP codes10 minutes (auto-expire)
Magic link tokensUntil used or expired
CSRF tokens24 hours
Account lockout status1 hour (auto-expire)
Uploaded filesRetained until manually deleted by organization
Generated documentsRetained indefinitely as part of audit trail (immutable)
Cached data5 minutes to 24 hours (auto-expire)

8. Your Rights

Depending on your jurisdiction, you may have the following rights:

  • Access: Request a copy of the personal data we hold about you
  • Correction: Request correction of inaccurate data
  • Deletion: Request deletion of your personal data (subject to legal retention requirements)
  • Portability: Request your data in a machine-readable format
  • Restriction: Request that we limit processing of your data
  • Objection: Object to processing based on legitimate interest
  • Withdraw consent: Where processing is based on consent, withdraw at any time

How to exercise your rights: Contact your organization administrator or email us. We will respond within 30 days.

Account deletion: Organization administrators can deactivate users (soft delete). Platform administrators can permanently delete user accounts, including removing all authentication data. When a user is permanently deleted, their owned data is transferred to a designated administrator account before removal.


9. Children's Privacy

myTransferPricing is a business-to-business platform designed for professional use by tax advisors, transfer pricing specialists, and corporate tax departments. The service is not intended for individuals under the age of 16. We do not knowingly collect personal data from children. If you believe a child's data has been submitted to our platform, please contact us immediately.


10. Email Communications

We send the following transactional emails (no marketing emails):

Email typeWhen sentContains
OTP verificationWhen you log in via OTP6-digit code, expiration time
2FA enabledWhen you enable two-factor authConfirmation, timestamp, IP address
2FA disabledWhen 2FA is turned offSecurity alert, timestamp, IP address
Welcome emailWhen your account is createdName, email, temporary password, login link
Admin welcomeWhen a platform admin account is createdName, email, temporary password, login link

Transactional emails are sent via Resend. You cannot opt out of security-related emails (OTP, 2FA alerts) as they are necessary for account security.


11. Changes to This Statement

We will update this privacy statement when we make material changes to how we handle personal data. The “Last updated” date at the top will reflect the most recent revision.

When significant changes occur (new data collection, new third-party providers, changes to data retention), we will notify users through the platform.


12. Contact Us

If you have questions about this privacy statement or how we handle your data, please contact us through your organization administrator or via the platform.

If you are unsatisfied with our response, you have the right to lodge a complaint with your local data protection authority.



© 2025 myTransferPricing. All rights reserved.