Privacy Policy

1. Controller

Philippe Ramón Hamerla, Agiou Georgiou 2-4, 8220 Chlorakas, Paphos, Cyprus

Email: team@merchavio.com

No data protection officer has been appointed, as the legal requirements for a mandatory appointment are not met. Please use the email address above for data protection enquiries.

2. Overview: what data we process

• Visiting the website: when you access the site, our server processes technically necessary connection data (IP address, time, requested address, browser identifier) to deliver the pages and protect them against misuse, e.g. by limiting repeated requests. We do not store access logs containing IP addresses. Images that a seller embeds on their link page from an external address are loaded by our server and delivered by us; your browser does not connect to the external server for them.
• Guide site shopspotting.com: this website is hosted on the same server as merchavio.com. When you access it, our server processes the technically necessary connection data (IP address, time, requested address, browser identifier) to deliver the pages; we do not store access logs containing IP addresses there either. There are no visit statistics on shopspotting.com. We do not set any cookies there and use neither your browser’s local storage nor a service worker. The question search box works entirely in your browser; what you type is not transmitted. Content, fonts and scripts come exclusively from our own server, and no third-party services are integrated into the pages (for name resolution by Cloudflare, see section 7). If you follow a link to merchavio.com, the other information in this Privacy Policy applies to the rest of your visit; your browser only transmits the domain shopspotting.com as the origin, not the individual page.
• Account (seller/Shopspotter/team/buyer): name, email, password (stored only as a bcrypt hash) or, for Google sign-in, the Google account identifier, business data (company, address, VAT ID), store data and uploaded product/media content, as well as proof of your confirmations at registration (time, version of the accepted terms, confirmation of business use) and the time you last used the dashboard (rounded to the full hour).
• Voluntary information (sellers): if you answer the questions “What is your store about?” and “How old are you?” in the dashboard, we store the topic you chose (for “Something else”, your own text) and your age group (e.g. 25 to 34 years, no date of birth). The information is voluntary; all features are available to you without it.
• Purchase: name and email address of the buyer, ordered products, amounts, order status and proof of the declarations made during the order process (ticked checkboxes, time, version of the texts and IP address).
• Payment: payment data is collected and processed directly by Stripe; we do not receive full card details, only payment and subscription status and pseudonymous identifiers (customer/subscription ID).
• Visit statistics of shops, link pages and our own website (merchavio.com): page viewed, time, type of event (e.g. view, cart, click on a link), the country (derived from the connection without storing your IP address) and the website you came from, of which only the domain (e.g. instagram.com) without any further parts of the address; on merchavio.com also campaign tags from the address you opened (utm parameters), the language of the page and the device type (computer, tablet or smartphone); only with your consent, additionally a random visitor ID (see section 4). If you register during the same visit, we store with your account which website or campaign and which page brought you to us.
• Heatmap of our website (merchavio.com), only with your consent: where you click on a page (the position on the page and on the clicked element, e.g. a button, and whether the element is clickable), how far you scroll down the page, the width of the window and the height of the page, plus the page viewed, the day and the screen size (computer or smartphone). We do not store a visitor ID, the time of day, any input in form fields or anything in your browser, and we only evaluate the data aggregated per page.
• Journeys on our website (merchavio.com), only with your consent: a random journey ID that we store in your browser (see section 4), plus every page viewed with date and time and the size of your browser window, how you scroll on the page and where you move the mouse pointer (scroll position and position of the mouse pointer in the browser window, at most ten times per second and only while something moves), every click with the spot where you clicked (on the clicked element and on the page), for links and buttons also their label and target, the device type (computer or smartphone) and the website or campaign you came from (only the domain or the campaign tags). We do not record any input in form fields or keystrokes; of the texts of the page only the label of clicked links and buttons mentioned above (at most 80 characters). To prove your consent, we store the version of the cookie notice and the time of your consent with the journey ID. If you sign up, we link this journey to your account; owners and administrators of our team then see it together with your name and email address, team members with the marketing role without these details. Our team can see which pages you viewed before and after signing up, what you clicked there and whether you later paid for a plan. Our team can also view the journey as a replay: the current version of our pages is loaded and your scrolling, mouse movements and clicks are reenacted on it with their original timing. From this we evaluate which journeys lead to sign-ups and paid plans. We do not make automated decisions about you on this basis and do not use the data for advertising. If you consented to the cookie notice in the version of 10 November 2026 or a later one, we record your journey in the same way while you are signed in to Merchavio (dashboard, settings and the other areas of your account): which areas you open, how you scroll there, where you move the mouse pointer and where you click. We do not record any content there, so no data of your customers, orders, products or your shop: we name clicks only by the type of element (for example “button” or “link”), labels only for the fixed menu items and tabs of Merchavio, and we replace identifiers in addresses with a placeholder. In the replay we show these areas in a sample account in which all content is only named by its topic (for example “customer name” or “password”, amounts only as “€ ••••”); our team does not see your data or that of your customers. If you sign in, we link the journey to your account, even if you did not sign up in this browser. This shows us how Merchavio is used and where steps are unclear.
• Partner programmes: the partner code of a link through which you arrived and the time of the click; upon registration or purchase, the attribution to that partner.
• Community, livestreams and voice rooms: your posts and chat messages and, if you actively participate or go live, camera/microphone data (audio/video) during the session.
• Chat in a shop’s app: your email address (to sign in with a code), the name you choose, your messages and when you sent them. In the open chat other users of the app see your name and your messages, never your email address; in the private chat only you and the seller see the messages.
• Notifications: if you allow web push in your browser, a device-related push identifier (subscription token).
• Team access: name, email address and assigned role/permissions of people a seller invites to their account.
• Finance and bookkeeping module (sellers): the receipts and invoices you upload, including the information they contain (also about third parties such as issuers), as well as your categories, notes, fixed costs and the evaluations calculated from them.
• Reports, cancellations and withdrawals: if you report content via “Report content”, we process the category, your explanation, the address concerned and, if you provide them, your name and email address. If you cancel via “Cancel contracts here”, we process the details from the form (contract, type and date of cancellation, email address, and name and reason if provided). If you withdraw from a contract via “Withdraw from contract here”, we process the details from the form (your name, the contract, the order number if provided, your email address for the acknowledgement of receipt and the reason if you choose to give one), the date and time of receipt and, later, the seller’s decision on the withdrawal; we do not store your IP address in this context. We and the seller concerned receive these details.
• Support chat and bug reports: if you write to us in the logged-in area (the “Team” area in the chat window) or report a bug there, we process your messages, your email address, your name and shop, and your plan. With a bug report, the app also sends the page of the app you currently have open, your browser identifier and the window size; this is shown to you before you send it.
• AI assistant “Merchavio AI” (logged-in area): your messages to the assistant, its replies, the conversation histories, the figures and content of your shop retrieved for this purpose, where your request requires it also data of individual customers or community members, and usage data per request (details in section 15).
• Guest authors: if you apply as a guest author or write for our guides, your application details and, once accepted, your author profile with photo, your articles and our feedback (details in section 16).
• Communication: content of your enquiries to our point of contact and related email metadata.

3. Purposes and legal bases (Art. 6 GDPR)

• Provision of the platform, accounts, storefronts, checkout and sign-in (including Google sign-in): Art. 6(1)(b) GDPR (contract/pre-contractual measures).
• Processing of connection data, prevention of misuse and fraud, IT security, stability: Art. 6(1)(f) GDPR (legitimate interest in a secure, functioning service).
• Proof of declarations at registration and purchase, including the IP address at purchase: Art. 6(1)(c) and (f) GDPR (obligations to provide evidence and legitimate interest in being able to prove conclusion of contract and consents).
• Sending transactional emails (order, account and password emails): Art. 6(1)(b) GDPR.
• Retention of invoice/accounting data and tax reporting obligations (e.g. DAC7): Art. 6(1)(c) GDPR (legal obligation).
• Visit statistics of shops and of our website without a visitor ID, attributing a registration to the website or campaign it came from, and counting clicks on partner links: Art. 6(1)(f) GDPR (legitimate interest of sellers and of us in measuring reach, evaluating our marketing and settling partner programmes; no usage profiles are created).
• Storing a visitor ID, partner codes and the marketplace attribution in your browser, and the heatmap and journeys of our website (to see which content is read and which buttons are used, which journeys lead to sign-ups and paid plans and how Merchavio is used, and to improve the pages and Merchavio): only with your consent, Art. 6(1)(a) GDPR in conjunction with Art. 5(3) of Directive 2002/58/EC (ePrivacy Directive) as implemented nationally.
• Attributing a referred account to a partner and settling the commission: Art. 6(1)(b) GDPR towards the partner and Art. 6(1)(f) GDPR towards the referred seller (legitimate interest in a traceable settlement).
• Provision of the finance and bookkeeping module including receipt upload, evaluations and export, as well as team access and connecting own domains: Art. 6(1)(b) GDPR. Where uploaded receipts contain personal data of third parties (e.g. of issuers), we process it on behalf of the respective seller, who is the controller in this respect (Art. 28 GDPR); the seller usually bases this processing on commercial and tax retention obligations (Art. 6(1)(c) GDPR) or on a legitimate interest in orderly bookkeeping (Art. 6(1)(f) GDPR).
• Community features (posts, chat, livestreams, voice rooms): Art. 6(1)(b) GDPR; camera/microphone use and web push notifications only take place with your express permission, Art. 6(1)(a) GDPR (consent).
• Handling reports of illegal content, including the confirmations of receipt: Art. 6(1)(c) GDPR in conjunction with Art. 16 DSA.
• Receiving cancellations and withdrawal declarations, sending the acknowledgements of receipt and forwarding them to the seller: Art. 6(1)(c) GDPR in conjunction with § 312k or § 356a German Civil Code (or the corresponding provisions of the applicable law), which oblige the seller as contracting party, and Art. 6(1)(f) GDPR (legitimate interest of the seller and of us in cancellations and withdrawals reaching the seller immediately and verifiably and in you receiving the required confirmation).
• Handling support requests and bug reports via the support chat, including notifying you of replies by email: Art. 6(1)(b) GDPR.
• Provision of the AI assistant, including storing the conversation histories and settling the AI allowance: Art. 6(1)(b) GDPR, for team members Art. 6(1)(f) GDPR (details in section 15).
• Evaluating whether accounts are in use and how far new accounts get during setup (time of last use, products created, payments connected, first sales) so that we can offer targeted help, prevent cancellations and improve the service: Art. 6(1)(f) GDPR (legitimate interest in working customer service and in developing our service). Only our team sees this evaluation.
• Evaluating which groups of sellers use Merchavio and pay for a plan (country, language, website or campaign of the registration, time of registration, setup progress, features used, chosen plan and time of the first payment) so that we can align our offer and our marketing: Art. 6(1)(f) GDPR (legitimate interest in aligning our offer). Your voluntary information on topic and age group is only included if you answer the questions; the legal basis is then your consent, Art. 6(1)(a) GDPR. You can change or delete this information at any time under Settings → Security and thereby withdraw your consent with effect for the future. Only our team sees this evaluation; we do not pass the information on and do not use it for advertising on other platforms.
• Reviewing applications as a guest author, providing the author area and publishing guest articles with an author profile: Art. 6(1)(b) GDPR (details in section 16).
• Sending marketing/newsletter emails: only with your consent, Art. 6(1)(a) GDPR; you can withdraw your consent at any time via the unsubscribe link or our point of contact.

4. Cookies and local storage

As technically necessary and permitted without consent, we store in your browser the sign-in token, the cart and local working states of the app, your settings (e.g. language) and your consent decision. In addition, a so-called service worker stores program files of the site in the browser cache so that it loads faster. On link pages (“link in bio”) and on shopspotting.com we store nothing in your browser, not even program files.

Only with your consent do we store a random visitor ID for the visit statistics of shops and of our website, partner codes for attributing referrals (platform partner programme and sellers’ partner programmes) and a cookie recording that you opened a shop via the marketplace. Also only with your consent do we measure on our website where people click and how far they scroll (heatmap, see section 2); for this we store nothing in your browser. Also only with your consent do we store a random journey ID and use it to record your path across the pages of our website and, from the version of the cookie notice of 10 November 2026, through the areas of Merchavio while you are signed in (there without content), linked to your account if you sign up or sign in (journeys, see section 2). Without consent we store and measure none of this; a partner code then only works until you reload the page. We do not use third-party advertising or analytics cookies. In the cookie notice you can accept everything, decline everything or, under “Choose”, decide on each purpose separately: statistics (visitor ID), recommendations (referral codes and marketplace link) and, on our website, heatmap and journeys.

Sellers see statistics on views, pages viewed, countries and the websites visitors came from for their shop, but no names, email addresses or IP addresses of visitors.

You can withdraw your consent at any time with effect for the future via the “Cookie settings” link (in the footer and on the “Cookies” page); the entries and cookies mentioned are then deleted, the heatmap stops measuring, and we delete the journeys stored for your journey ID, including the link to your account. If you have signed up, you can also delete the journeys linked to your account at any time in the dashboard under Settings → Security, including from another device. In our backups, deleted journeys remain until the backups expire (at most 365 days, section 9) and are only used to restore after an outage; we no longer accept a deleted journey ID afterwards. If you choose to sign in with Google or make a payment, third-party services (Google sign-in, Stripe, PayPal) are integrated that may set or read their own cookies. Details, storage periods and providers can be found on the “Cookies” page.

5. External resources (scripts/fonts)

The content, fonts and scripts of our website are generally delivered from our own server (self-hosted); simply browsing the platform does not establish connections to third-party CDNs (e.g. Google Fonts).

Exceptions: (a) only if you click “Continue with Google” or “Sign up with Google” on the sign-in or registration screen are you redirected to Google’s sign-in page. (b) For payment, you are redirected to a secure page hosted by Stripe or PayPal. (c) If you, as a seller, change the payment method of your Merchavio plan in the dashboard, only then does your browser load Stripe’s payment form (js.stripe.com) into the page. In the process, Stripe receives your IP address and technical information about your device; you enter your payment details directly with Stripe and they never reach our servers (Art. 6(1)(b) GDPR).

Content embedded by sellers: sellers can embed third-party content on their storefronts, product pages and in communities, in particular videos (e.g. YouTube, Vimeo, Twitch) and review widgets (e.g. Trustpilot). When such content is loaded, your IP address is transmitted to the respective provider, which may set its own cookies. Where possible, the content is only loaded after you click. Course and product videos uploaded by sellers themselves are delivered directly from our object storage at Cloudflare (see section 7).

6. Sign-in with Google (Google Sign-In)

No Google script is loaded on our pages. Only when you click “Continue with Google” or “Sign up with Google” on the sign-in or registration screen are you redirected to Google’s sign-in page; before that, no connection to Google is established. With the redirect, your IP address is transmitted to Google. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (for users in the EEA); the parent company is Google LLC, USA.

After successful sign-in, Google sends us a signed token with your email address, your name and a Google account identifier, which we use to create or match your account. Google may set its own cookies and process data in this context.

The legal basis is Art. 6(1)(b) GDPR (sign-in requested by you) or, where cookies requiring consent are set, your consent given by clicking the Google button (Art. 6(1)(a) GDPR). If you use email/password sign-in instead, no connection to Google is established.

7. Recipients and processors

• Hosting: Hetzner Online GmbH, Germany (server location EU); processing on our behalf under Art. 28 GDPR.
• Object storage and name resolution: Cloudflare, Inc. (USA). Uploaded files and media, including receipts from the finance and bookkeeping module, and our backups are stored in the “Cloudflare R2” object storage (region EU). Purchased files, uploaded course and product videos and recordings of livestreams are delivered directly from this storage to your browser; in the process, Cloudflare receives your IP address. Cloudflare also operates the name resolution (DNS) of our domains merchavio.com and shopspotting.com; the other traffic when you visit these websites does not pass through Cloudflare. Transfers to the USA are safeguarded by Cloudflare’s certification under the EU-U.S. Data Privacy Framework and EU standard contractual clauses.
• Payments (card, SEPA and others): Stripe Payments Europe, Ltd. (Ireland); in the course of payment processing, Stripe may transfer data to Stripe, Inc. (USA), safeguarded by the EU-U.S. Data Privacy Framework and standard contractual clauses.
• Payments (PayPal): PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg. If you choose PayPal for a purchase or a subscription, your name, email address, amount and order/subscription ID are transmitted to PayPal for payment processing; PayPal is independently responsible for this. If the seller has connected their own PayPal business account, we only technically create the subscription or payment at PayPal using the seller’s credentials and in the seller’s name; the buyer data mentioned (name, email, amount, order/subscription ID) is processed in this context, and the seller is the controller for this PayPal merchant relationship. If sellers pay for their Merchavio plan via PayPal, we only receive the payment and subscription status and pseudonymous identifiers from PayPal.
• Sign-in: Google Ireland Limited / Google LLC (USA) for the optional Google sign-in, safeguarded by the EU-U.S. Data Privacy Framework and standard contractual clauses.
• Email delivery: sending of transactional emails and, only with your consent, marketing emails via Brevo (Sendinblue GmbH, Cologne, or Brevo SAS, France, EU) as processor.
• Mailboxes: Zoho Corporation (USA) provides the mailboxes of our contact and support addresses (data centre USA). If you email us, your message, your email address and any attachments are stored there; processing on our behalf under Art. 28 GDPR; transfers to the USA are safeguarded by the EU-U.S. Data Privacy Framework and/or EU standard contractual clauses.
• Live streaming, voice rooms and video communities: LiveKit, Inc. (USA) operates the real-time audio/video infrastructure as “LiveKit Cloud”. If you join a livestream or voice room or go live yourself, the audio/video and connection data transmitted is processed via LiveKit. Where we additionally use our own TURN server as a connection aid, it runs on our server in the EU. Transfers to the USA are safeguarded by EU standard contractual clauses.
• AI assistant: DeepInfra, Inc. (USA) runs the “DeepSeek V4 Flash” language model for the AI assistant in the logged-in area; processing takes place in the USA. The model comes from DeepSeek but runs exclusively on DeepInfra’s servers; DeepSeek receives no data. Only if DeepInfra has an outage do we use the “gpt-oss-120b” language model of Groq, Inc. (USA) or the “Claude” language model of Anthropic Ireland, Limited (Ireland) instead; at Anthropic, processing also takes place outside the EU, in particular in the USA by Anthropic, PBC and its service providers. Only the data listed in section 15 is transmitted, and only via our server. None of the providers uses the content to train its models. Transfers to the USA are safeguarded by EU standard contractual clauses.
• Push notifications: if you enable web push in your browser, the (encrypted) notification is delivered via the push service of your browser or device manufacturer; your browser selects this service.
• Sellers: when you make a purchase, the respective seller receives the data required to perform the contract (name, email, order data) as an independent controller and may contact you within the legal limits (or with your consent). The seller also receives your cancellations and withdrawal declarations (see section 2).
• Partners: if you registered as a seller via the link of a partner of our partner programme, that partner sees in the partner portal the name of your shop, your partially masked email address, the registration date, your plan and status, and the resulting commissions. The partner is an independent controller in this respect; the legal basis for the transfer is Art. 6(1)(f) GDPR (traceable commission settlement).
• App products (“Works with Merchavio”): if you buy a software product (app) from a seller, we transmit the order data required for activation (name, email, order number, plan), signed and encrypted in transit, to the app service configured by the seller; the seller is the controller for this processing.

The technical service providers listed above (Hetzner, Cloudflare, Stripe, PayPal, Google, Brevo, Zoho, LiveKit, DeepInfra, Groq, Anthropic) are also the sub-processors within the meaning of the Data Processing Agreement; the list there (page “DPA (Art. 28)”, section 7) is identical to this list. Sellers, partners, app providers and your browser’s push service, by contrast, are independent controllers or not processors for us.

8. Transfers to third countries

Where data is transferred to recipients in the USA (Cloudflare, Stripe, Google, Zoho, LiveKit, DeepInfra, Groq, Anthropic), the transfer is based on an adequacy decision (EU-U.S. Data Privacy Framework) and/or on EU standard contractual clauses under Art. 46(2)(c) GDPR together with supplementary safeguards. Hetzner and Brevo process within the EU/EEA; PayPal (Europe) is based in Luxembourg. A copy of the safeguards can be requested via our point of contact.

9. Storage period

• Connection data: only for the duration of the request; we do not keep access logs containing IP addresses. Server error logs are limited in size and automatically overwritten.
• Account data: until the account is deleted; the data is then deleted unless statutory retention obligations apply.
• Backups: we keep copies of the database for 14 days on our server and for up to 365 days in the separate storage (section 7), solely to restore data after an outage; they are then deleted automatically. The shorter periods in this section apply to ongoing operations; we do not use data in backups for any other purpose.
• Voluntary information on topic and age group: until you delete it under Settings → Security, at the latest until the account is deleted.
• Order and invoice data: in accordance with the statutory commercial and tax retention periods (usually 6–10 years). We store the proof of declarations at registration and purchase together with the account or order data.
• Visit statistics, heatmap, journeys and clicks on partner links: 90 days, then automatically deleted.
• Reports, cancellations and withdrawal declarations: three years from receipt as proof of handling, then automatically deleted.
• Support requests and bug reports: three years after the last message, then automatically deleted.
• AI assistant: conversation histories until you delete them in the chat, at most 12 months after the last message, then automatically deleted; usage data without content 13 months, then automatically deleted. If the account is deleted, we automatically delete both within one day. At Anthropic, inputs and outputs are usually deleted within 30 days (see section 15).
• Entries in your browser: visitor ID and journey ID until you withdraw consent, delete them in your browser or your decision expires after 12 months; your consent decision 12 months; sellers’ partner codes 30 days; the platform partner programme’s partner code and the related cookie 90 days; marketplace cookie 24 hours.
• Attribution of an account to a partner: as long as commissions can arise from it, then in accordance with the tax retention periods for the settlements.
• Community content (posts, chat messages): until deleted by you, the seller or a moderator, or when the community membership ends. Live audio/video from streams/voice rooms is not stored permanently by us unless a recording is expressly offered and enabled.
• Chat in a shop’s app: messages until deleted by you or the seller, at most 12 months, then deleted automatically.
• Guest authors: declined applications six months after the decision, applications not decided on twelve months after receipt, unpublished drafts 30 days after the end of the cooperation, unused photos and images after one day, each automatically; profile, photo and published and offline articles as described in section 16.
• Receipts and evaluations in the finance and bookkeeping module: until deleted by the seller; the seller decides on deletion within the commercial and tax retention periods applicable to them.

10. Your rights

• access (Art. 15 GDPR) to the data stored about you,
• rectification (Art. 16) and erasure (Art. 17),
• restriction of processing (Art. 18),
• data portability (Art. 20),
• objection to processing based on legitimate interests (Art. 21),
• withdrawal of consent given, with effect for the future (Art. 7(3)).

An informal message to team@merchavio.com is sufficient to exercise these rights.

11. Right to lodge a complaint

You have the right to lodge a complaint with a data protection supervisory authority, in particular with the authority responsible for us: Office of the Commissioner for Personal Data Protection, Iasonos 1, 1082 Nicosia, Cyprus, www.dataprotection.gov.cy, or with the supervisory authority of your habitual residence.

12. Obligation to provide data

Providing the data requested at purchase or registration is necessary for concluding the contract; without it we cannot provide the service. Beyond that, there is no obligation to provide data.

13. No automated decision-making

We do not carry out automated decision-making, including profiling with legal effect, within the meaning of Art. 22 GDPR. If you have consented to journeys and signed up or signed in, we evaluate your journey together with your account (profiling within the meaning of Art. 4(4) GDPR, see section 2); we do not make decisions about you on this basis. The payment service provider Stripe may carry out automated checks for fraud prevention; Stripe is independently responsible for this. The AI assistant does not make such decisions either: it only acts on your instruction in your own account (see section 15).

14. Data of sellers’ end customers

Where we process customer data on behalf of a seller (e.g. the seller’s order/customer list), the seller is the controller and we are the processor. The Data Processing Agreement (page “DPA (Art. 28)”) also applies to this processing.

15. AI assistant “Merchavio AI”

In the logged-in area, sellers and their team members can use an AI assistant. There you are writing with an AI system, not with a human; the replies are generated automatically and may contain errors. Using it is voluntary; all features of the platform are available to you without the assistant.

The “DeepSeek V4 Flash” language model is run by DeepInfra, Inc. (USA) as our processor under Art. 28 GDPR; processing takes place in the USA. The model comes from DeepSeek but runs exclusively on DeepInfra’s servers; DeepSeek receives no data. Only if DeepInfra has an outage do we use the “gpt-oss-120b” language model of Groq, Inc. (USA) or the “Claude” language model of Anthropic Ireland, Limited (Dublin, Ireland) instead, in each case likewise as our processor; at Anthropic, processing also takes place outside the EU, in particular in the USA by Anthropic, PBC and its service providers. The model is called exclusively from our server; your browser does not connect to any of the providers.

When you ask the assistant a question, we transmit to the provider of the language model:

• Your message and the previous history of this conversation.
• Context information: date, language, name of your shop, your plan, your first name, the period selected on the home screen, whether critical actions require confirmation, the address of your shop and whether your storefront is published, and, where applicable, the draft of a discount code. If you ask how far your shop is set up (for example whether you can sell yet), additionally these setup details, without revenue, balances or bank details: the status of your plan and your trial, whether your email address is confirmed, which selling details are still missing (without their content), whether Stripe is connected and enabled for payments, your own domain and whether it is confirmed, and the number of your published products.
• The results of the functions the assistant retrieves in your browser for this purpose: figures and analyses of your shop (e.g. revenue, orders, new members, cancellations, visitor numbers, conversion, pages where visitors drop off, best-selling products), your products and discount codes, notes on open matters, and sections and texts of your storefront.

The assistant only retrieves data of individual customers or community members (e.g. name, email address, orders, subscription and membership status) if your request requires it, for example if you ask it to go through your member list, remove a member from the community or cancel their subscription. Only then is this data sent to the provider of the language model, and only as far as the task requires. The assistant never receives payment data such as card or account numbers. Please do not enter data of third parties or special categories of personal data (e.g. health data) in the chat unless it is necessary for your question.

DeepInfra does not use the content to train models and does not pass it on to third parties. DeepInfra holds inputs and outputs only in working memory during processing and does not store them; only technical data without content is logged (e.g. request ID, cost). Under its data processing agreement, Groq does not use the content for its own purposes, so not for training models either, and as a rule does not store inputs and outputs. Only to fix technical outages or when abuse is suspected does Groq log them temporarily, for at most 30 days. Under its terms, Anthropic does not use the content to train its models and usually deletes inputs and outputs within 30 days. Anthropic only keeps them longer, for up to two years, if they are identified as a violation of Anthropic’s usage policies, or if the law requires it.

The assistant answers questions, analyses your figures and, on your instruction, carries out actions in your account, e.g. creating a discount code, changing the storefront as a draft, removing a member from the community, cancelling a subscription or sending a message to our support. It works with your permissions and cannot do more than you can yourself. You confirm critical actions (publishing, messages to support) beforehand in “Manual” mode; in “Auto” mode the assistant carries them out directly and labels them as executed automatically. Actions affecting individual customers or members (e.g. removing a member, cancelling a subscription) are always carried out only after your confirmation, even in “Auto” mode; the decision is therefore always yours. We treat a message to support sent via the assistant like any other support request.

We store your conversation histories (with the person who held them) and, per request, usage data without content (time, model, number of tokens processed, cost), which we use to settle the AI allowance of your plan or trial. If the allowance is used up, a help assistant without AI answers your questions from our help articles; nothing is transmitted to an AI provider in that case. Overviews such as the summary, things that need attention and live visitors are calculated by your browser itself, without an AI provider.

Towards sellers, the legal basis is Art. 6(1)(b) GDPR (provision of the feature of your plan or trial that you use). If team members use the assistant, the legal basis is Art. 6(1)(f) GDPR (legitimate interest of the seller and of us in providing the feature booked by the seller to the seller’s team as well). Where messages or retrieved content contain personal data of your customers or other third parties, we process it on behalf of the seller (section 14 and DPA). The transfer to the USA is safeguarded by EU standard contractual clauses (section 8).

16. Guest authors

Application: If you apply to write for our guides as a guest author, we process your name, email address, website, the profiles you provide, your niche, your information on experience and topic idea, your writing samples and the time and version of the accepted terms for guest authors. Mandatory are name, email address, niche, your information on experience and the topic idea; without them we cannot review the application. Website, profiles and writing samples are optional. We use this information to review the application and reply to you. If we accept the application, we take your name, niche, website and profiles as a suggestion for your author profile; you can change them in the author area. An automatic filter scans applications, profile information and articles in advance for terms we do not publish; decisions are always made by people. The legal basis is Art. 6(1)(b) GDPR (pre-contractual measures).

Author area: If we accept the application, we create an author account. In it we process your email address for sign-in codes, the time of your last sign-in, your profile information (name, photo, role, introduction, niche, website, profiles), your drafts and articles, your topic proposals, your notes to the editors and our feedback. We store your photo and the images you add to articles on our server in the EU. We store sign-in codes only as a check value; they are valid for 15 minutes, sign-in links from our emails for at most 7 days, and are deleted one day after they expire. For signing in, we store a sign-in token in your browser that is valid for 30 days or until you sign out (technically necessary, see section 4). The legal basis is Art. 6(1)(b) GDPR (cooperation under the terms for guest authors).

Publication: Your profile only becomes visible once your first article is published. We then publish your name, photo, role, introduction, niche, website, profiles and your articles with the link to your website and, where applicable, the note that you used AI when writing, on your profile page, in the author box below your articles and in structured data for search engines. Photo, role, introduction and profiles are optional. This information is therefore accessible to anyone on the internet and can be captured by search engines. The legal basis is Art. 6(1)(b) GDPR; under section 7 paragraph 3 of the terms for guest authors, you can request at any time that we no longer publish your name and profile. If none of your articles is online any more, we take the profile offline.

Recipients: hosting and email delivery run via the service providers named in section 7. The platform notifies us about new applications, submitted articles, profile changes and topic proposals in our internal administration area, stored on the same servers as the platform, with your name, your email address and a short summary; we delete these notifications no later than 12 months after receipt. If you email us yourself, your message is stored in our mailbox at Zoho (data centre in the USA, safeguards see section 8). There are no other recipients; what we publish (see above) can be accessed by anyone.

Storage period: We automatically delete declined applications six months after our decision so that we can answer queries, and applications we have not decided on twelve months after receipt. Accepted applications become part of the author account and are deleted with it. We store the data in the author account for the duration of the cooperation. When it ends, we delete unpublished drafts, unapproved revisions and your notes within 30 days; if we only block access, they are kept. Photos that are no longer used in any profile or profile draft, and images that are no longer used in any of your drafts or articles, are deleted after one day. Profile, photo and published articles remain online under the terms for guest authors until you request that we no longer publish your name and profile (section 7 paragraph 3 of the terms). We then delete profile, photo, application and drafts within 14 days and take your articles offline. We keep the offline articles, your email address and the record of the accepted terms for three more years in order to assess and defend claims relating to the articles (Art. 6(1)(f) GDPR; you can object under Art. 21 GDPR), and then delete them. We cannot delete copies already made by search engines or third parties; on request, we apply for removal from Google Search.

17. Changes

We adapt this Privacy Policy when the processing or the legal situation changes. The version published here applies.