1. Introduction

This privacy policy describes how AGTT SmartSuite, a Microsoft Excel add-in developed by AGTT, handles your data. We value your privacy and are transparent about our data practices.

AGTT SmartSuite is a professional tool for accounting and audit firms that streamlines audit documentation, client questions, and sampling processes within Microsoft Excel.

2. Data Controller

AGTT is the data controller for the processing of personal data in connection with AGTT SmartSuite.

Contact details:

• Company name: AGTT
• Website: www.agtt.nl
• Email: info@agtt.nl

• Address: Lange Kleiweg 14 Unit 1.15, 2286GK in Rijswijk.

3. What data do we process?

3.1 Local data processing (current version)

AGTT SmartSuite currently processes all data locally within your Excel workbook. This means:

• Documentation data is stored in custom document properties of your Excel file
• Client questions are stored in custom document properties of your Excel file
• Sampling configurations are stored in custom document properties of your Excel file
• Language preferences are stored in custom document properties of your Excel file

NO data is sent to external servers in the current version.

3.2 Future cloud features (DocSense)

In future versions, optional cloud features may be introduced, such as document processing via Azure Document Intelligence. If you choose to use such features:

• You will be informed and asked for consent before any data leaves your local environment
• Cloud processing takes place in EU data centers compliant with GDPR requirements
• Documents are processed but not stored on our servers
• After processing, results are returned and source data is immediately deleted

3.3 License and account data

For access to paid features (DocSnap, DocSense), we process:

• Email address (for license validation via Azure AD)
• Organization name
• License level and validity

This data is processed based on the performance of our contract with you.

4. Purposes and legal basis

5. Data sharing

We do not share your data with third parties, except:

• Microsoft Azure: For license validation (Azure AD) and future cloud processing (Azure Document Intelligence)
• Legal obligations: If we are legally required to do so

6. Security

We take appropriate technical and organizational measures to protect your data:

• All communication is via encrypted HTTPS connections
• Azure services comply with ISO 27001, SOC 2, and GDPR requirements
• Local data is protected by Microsoft Excel’s security measures and your organization’s policies

7. Your rights

Under GDPR, you have the following rights:

• Right of access – You can request what data we process about you
• Right to rectification – You can have incorrect data corrected
• Right to erasure – You can request deletion of your data
• Right to restriction – You can have processing restricted
• Right to data portability – You can receive your data in a structured format
• Right to object – You can object to certain processing activities

To exercise your rights, please contact us at info@agtt.nl.

8. Retention periods

• Local workbook data: As long as you retain the Excel file (under your own control)
• License data: During the term of your license plus 7 years for financial administration
• Cloud processing: Source data is deleted immediately after processing; results are not stored

9. Supervisory Authority

If you have a complaint about our processing of your personal data, you can contact the Dutch Data Protection Authority:

Autoriteit Persoonsgegevens

• Website: www.autoriteitpersoonsgegevens.nl
• Phone: +31 88 1805 250
• Postal address: Postbus 93374, 2509 AJ The Hague, Netherlands

10. Changes

We may change this privacy policy from time to time. Significant changes will be communicated through the add-in or by email to license holders. The date of the last change is stated at the top of this document.

11. Contact

For questions about this privacy policy or the processing of your data:

Email: info@agtt.nl Website: www.agtt.nl