Orvikon — AI / API-Data Use Policy
Version: 2026-07-01 · Last updated: 1 July 2026
Internal policy (not user-facing). This is the written commitment Xero’s audit (developer-platform T&Cs clause 38) asks to see. The user-facing statement of the same commitment lives in the Privacy Policy §4/§7. No external legal review required, but it must be kept accurate as the platform evolves.
1. Why this policy exists
Xero’s developer-platform T&Cs (introduction and clause 7.b.i/ii) require that “API Data” — any information accessed, received, transmitted or generated through the Xero APIs, in raw or processed form — is:
- never used to train, fine-tune, adapt or enhance any AI model (including machine learning tools, large language models, or predictive-analytics tools); and
- never passed to another third party without the associated user’s consent, and never for any purpose that conflicts with Xero’s terms.
Xero may audit compliance (clause 38, up to twice a year) and may ask for reasonable evidence. This document is that evidence.
2. Our commitment
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No AI/ML training. Xero-sourced data — and, more broadly, any user financial data (invoices, fees, paid-status, accounting data) — is never fed into the training, fine-tuning, adaptation or enhancement of any AI or machine-learning model, ours or a third party’s.
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No third-party analytics on financial data. User financial data is not sent to any third-party analytics, profiling or data-enrichment service.
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No undisclosed passthrough. API Data is passed to a third party only where it is necessary to provide the Service, the third party is disclosed in the Privacy Policy sub-processor list, and the user’s consent covers that flow (see §4). It is never sold or aggregated-and-supplied to another app or third party.
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Developer practice. Developers and support staff do not paste real Xero data or real user financial data into AI tools (chat assistants, code assistants, or any external AI service) during development, debugging or support. Use synthetic or redacted data instead.
3. Standing constraint — new AI features
If Orvikon ever adds a feature that applies AI or ML over job, invoice or Xero-sourced data, that feature must be re-reviewed against this policy and against Xero T&Cs clause 7 before it ships. This clause is the trip-wire: no AI-over-financial- data feature is built without an explicit review recorded against it.
4. Consent basis
The Privacy Policy discloses the sub-processors that store or handle Xero-sourced data (for example Supabase, which hosts the database that holds paid-status data synced from Xero). The user’s acceptance of the Terms and Privacy Policy at signup (Slice 15N) is the consent that covers those disclosed flows. Clause 7.b.ii’s “no passthrough without consent” is satisfied because every third party that touches the data is disclosed and consented to; nothing is passed to an undisclosed third party.
For the Privacy Policy legal review: confirm that the signup consent (15N) is worded to cover the disclosed sub-processor flows for Xero-sourced data.
5. Related documents
- Privacy Policy — the user-facing AI-data-use statement and the sub-processor list.
- Incident Response runbook — breach handling for Xero-sourced data.