Legal

Privacy

Last updated: 15 October 2026

Last updated: 2026-10-15 · Controller: lakör GmbH & Co. KG, Am Kreuzgraben 5, 18146 Rostock, Germany, support@easyaiactlabels.com (full details in the Legal Notice)

This is a courtesy translation. The German version is the legally binding one.

In short

I am a Shopify app and I read the images of your store to find provenance data. I store no images, no customer data and no orders. The label in your store loads nothing from my server and sets no cookies. When you uninstall me, your data is deleted. Excepted is what I need for settling commission with partners (paragraph “Partner programme” under “Where your data is located”). If you use the support chat in the app, I send your message, your first name and the technical state of the app to Anthropic (USA), never your store address, never your e-mail address and never credentials.

Who this policy applies to

To you as a merchant who uses Easy AI Act Image Labels in your Shopify admin, including the support chat in the app (section “Support chat in the app”).
To visitors of these info pages (home page, FAQ, support, legal pages).
Not to the visitors of your store. The label script runs in your customers’ browsers but does not talk to me: no network request to my server, no cookie, no local storage, no audience measurement. Shopify delivers all files of the label from its own infrastructure. I do not learn who visits your store. You therefore do not have to name me as a recipient of visitor data in your own privacy policy.

What I read in your store

During installation Shopify asks you for these permissions:

Read products (read_products): product titles and the assignment of which image belongs to which product. That is how I can tell you where an image is used.
Read files (read_files): your file library, file names, upload date, image dimensions, image URLs and the usage index. For the check I download the original file of each image, but only the first 512 kilobytes, which is where provenance data lives. I read the metadata blocks (C2PA, IPTC, XMP) from it and discard the image data immediately. I store no images.
Read themes (read_themes): the settings files of your themes, to see whether the label is turned on and which images sit in theme sections. I never write to your theme.
Read shop locales (read_locales): which languages your store offers, so that the label can appear in your customer’s language when you choose the dynamic language mode.

I request no further permissions. In particular I have no write access to products, files, themes or translations.

What I do not read

No customers, no orders, no payments, no addresses, no analytics. I have no permission for these areas and do not request it.

What I write in your store

Two app-owned metafields (ai_badge.enabled, ai_badge.config): the on/off switch and the list of images you confirmed as AI-generated or AI-modified. These fields belong to the app and disappear with it.
Nothing else. I change no products, no images, no image descriptions, no themes, no menus. A technical block list in the code prevents this; it is checked with every deployment.

What I store on my side

What	Why	How long
Your store address (`your-store.myshopify.com`)	All data is assigned to your store	until deletion after uninstall
Access token for the Shopify API (stored encrypted)	So that I may read on your behalf	until uninstall; then deleted immediately
Scan results per image: file name, image URL, dimensions, location, provenance data found (for example “Created with Adobe Firefly”), your decision and the time you set the label	The actual purpose of the app; on the Free plan the time decides which 25 labels appear in your store	until deletion after uninstall
Settings (locations, corner, size of the label)	Your configuration	until deletion after uninstall
Interface language (your choice in the app’s language menu and the language last seen in the app)	So that the app appears in your language and notices I send without the app being open (for example e-mails about your plan) are written in that language	until deletion after uninstall
Storefront password of your store, only if you enter it for the self-test (password-protected stores)	So that the self-test can load your store pages and count the labels	until you remove it or until deletion after uninstall; never in the log, never in API responses, never passed to third parties
Run history (date, counters per scan)	So that you can see what is new since the last scan	until deletion after uninstall
Automation setting (switch state, time it was turned on, time of the last check run, counters of new, automatically labelled and closed-without-label files)	So that I can check new images daily and after product changes and show you what happened	until deletion after uninstall
Debounce marker after a product change (only your store address, no product data)	So that many changes in quick succession trigger only one check run	15 minutes
Log entries (event, store, truncated IP address, time)	Security and troubleshooting; the IP is truncated by its last octet or its second half	90 days, then removed automatically
Contact person of a support request (your name, your e-mail address only if you provide it)	So that the support team knows whom it is talking to and can answer you if needed; the details last used as a suggestion for your next request	with the request, 90 days after the last message; the suggestion until deletion after uninstall
Support conversations (your messages, answers by the AI and by the support team, topic, status, language)	So that you see your requests and the answers in the app and the support team can follow the case	90 days after the last message, or earlier if you delete the request in the chat; at the latest on uninstall
Bug reports from the chat (title, description, theme name and version, technical app state)	So that I can reproduce and fix the bug	180 days; at the latest on uninstall
Read-access consent (time of consent and its expiry, stored in the request)	Proof of your consent and automatic end of the read access	7 days from consent or until you withdraw it
Collaborator request code (four digits, stored encrypted), only if you enter it in the chat	Access request by the support team in the Shopify Partner Dashboard	until the request is submitted, until you withdraw it or 14 days at the latest; never in the log
Counter of support messages per store and day (a single number)	Usage limit against abuse of the chat	2 days
Review prompt record (the times I asked and the result code from the Shopify dialog, including “Don’t ask again”)	So that I do not ask you repeatedly	until deletion after uninstall
Plan status (your plan Free or Unlimited, status and id of your subscription at Shopify, interval, start of the free trial, time of a cancellation in the app, end of the grace period, cut-off date and times of my notices after your store stops being a development store)	So that I know which plan applies and what it covers (number of labels, automation, language) and can show you the state on the Plan page	until deletion after uninstall
Redeemed code (code, type and extent of the benefit, time of redemption; for a code from the partner programme, the partner’s identifier and whether the assignment to the partner succeeded)	Book the benefit with Shopify, one code per store, settle the partner’s commission	until deletion after uninstall
Lock record for a redeemed code: the code, the type of code, the time of redemption and a check value calculated from your store address that does not contain it; for a permanent discount also its amount	So that only one code applies per store, also after a reinstallation, each waiting list code only once and a permanent discount continues to apply after a reinstallation (Section 7 (9) of the terms of use)	400 days after redemption, also after uninstall; for a permanent discount 400 days after the last day on which Unlimited was subscribed with this discount (test subscriptions do not count)
Number of wrong code entries (a number only)	Protection against trying out codes	1 hour
Inventory list of your image files (file id, upload date, file name without the image)	So that I can show you the number of images in your store and detect which images you deleted; deleted images do not count as labels	until deletion after uninstall
Store e-mail address from your Shopify admin	Only for notices about your plan (advance notice and the message that Free applies after your development store becomes a paid store); I send no advertising	until deletion after uninstall

Provenance data in images can contain names, for example the name of a photographer or of the signing tool. I store this data only because it is the evidence for the proposal you see.

I do not store: image files, alt texts, customer data, orders.

Shopify informs me by webhook about product changes (products/update) and theme publications. I do not read the content of the product notification and store nothing from it; it only triggers a check run that, like every scan, reads files and products through the Shopify API. Customer data is not part of it.

Support chat in the app

There is a support chat in the app. It is voluntary; you can still reach me by e-mail at support@easyaiactlabels.com. When you ask a question in the chat, this happens:

Contact person. Before each new request you confirm your name and, if you like, an e-mail address. I store both with the request; I suggest the details last used again for your next request.

Answer by AI. To answer you right away, I send your message text, the previous history of this one request and a technical summary of the app state to Anthropic (Anthropic, PBC, San Francisco, USA; the contracting entity for customers in the EU is Anthropic Ireland Limited, Dublin). Before that, I replace e-mail addresses, phone numbers and account numbers (IBAN) in the message text with placeholders; the support team sees your message unchanged. The summary contains your settings (locations, corner, size of the label), the counters of the last scan, name and version of your theme, the state of the app embed and of the self-test, and the plan status. It does not contain: your store address, your e-mail address, access tokens, the storefront password, file names, image URLs or images. Anthropic processes this data as my processor on the basis of a Data Processing Addendum with EU Standard Contractual Clauses, does not use inputs and outputs to train its models, and stores them under its terms only briefly for abuse detection. Answers by the AI are general information and implementation help, not legal advice; checking your obligations remains your responsibility. Never enter passwords in the chat. I never need credentials, and the support team never asks for them.

Handover to the support team. If the AI cannot help, if you report a bug or if you ask for a person, I hand the request over to the support team. For this the app posts to a private Slack channel of the support team: your store address, your name and, if given, your e-mail address, the message text or an excerpt of it and the technical summary from above. Answers from the support team appear in your chat. Bug reports I additionally store as a separate record (title, description, theme, app state) so that I can fix the bug.

Read access, only with your explicit consent. If you choose “Allow read access” in a request, the support team may, for 7 days and through the app’s existing access token, read products, files and theme settings of your store to follow the case. This is consent; you can withdraw it in the chat at any time, and the read access then ends immediately. No new permissions arise from it, the read permissions listed above remain, and even with read access the support team never writes to your theme.

Collaborator request code, only with your explicit consent. For a fix in your theme the support team needs collaborator access to your store, which you approve yourself in Shopify; the app itself never writes to the theme. If you enter the four-digit collaborator request code from your Shopify admin in the chat for this purpose, I store it encrypted, transmit it to the support team through the private Slack channel, and the support team uses it exclusively for the access request in the Shopify Partner Dashboard. The code is deleted as soon as the request is submitted, when you withdraw it in the chat or after 14 days at the latest. Withdrawing in the chat only deletes the code; access already granted you revoke in your Shopify admin under Users. For this too I need no password.

Review. After a solved request or on the Overview page of the app I may ask whether you would like to review the app in the App Store; with “Don’t ask again” I store only that decision. There is no reward for a review. The dialog is Shopify’s own review dialog. I only learn whether you clicked and whether Shopify showed the dialog; the review itself is processed by the Shopify entity under its privacy policy.

Usage limit and deletion. So that the chat is not abused, I count the messages per store and day; once the limit is reached, you can continue by e-mail. You can delete individual requests in the chat yourself. I delete conversations 90 days after the last message, bug reports after 180 days, the daily counters after 2 days. I delete the app’s posts in the support team’s Slack channel (containing store address, name, e-mail address, message text and, if applicable, the collaborator request code) 90 days after the last message of the request, also after an uninstall; replies of the support team in the channel are deleted by Slack after one year at the latest. With the uninstall all of this is deleted immediately (deletion command shop/redact).

Without the Anthropic connection (for example during an outage) the chat works as a form: your message then goes directly to the support team via Slack, without an AI answer.

Where your data is located

Easy AI Act Image Labels is operated on the platform of Cloudflare, Inc. (San Francisco, USA). Cloudflare is my processor under a contract pursuant to Art. 28 GDPR. The database (Cloudflare Workers KV) stores in data centers in the EU and the USA and keeps short-lived copies in Cloudflare locations worldwide. The transfer to the USA relies on Cloudflare’s certification under the EU-US Data Privacy Framework and, in addition, on the EU Standard Contractual Clauses.

For the AI answers in the support chat I use Anthropic (Anthropic, PBC, 548 Market St, San Francisco, CA 94104, USA; for customers in the EU Anthropic Ireland Limited, Dublin). Anthropic is my processor under a Data Processing Addendum pursuant to Art. 28 GDPR. Processing takes place in the USA; the transfer relies on the EU Standard Contractual Clauses (Art. 46 GDPR), which are part of the addendum. Anthropic does not use the transmitted inputs and outputs to train its models. Only message text (with placeholders instead of e-mail addresses, phone numbers and account numbers), conversation history and technical app state are transmitted, without store address, without names, without e-mail address and without credentials (section “Support chat in the app”).

Payment. Payment data (payment method, invoices) is processed exclusively by the Shopify entity under its privacy policy; I see no payment data and receive from Shopify only the status of your subscription (for example active, cancelled) and its id.

Codes. If you enter a code, I check it first in the app, then with the partner programme and the waiting list of Easy AI Act Image Labels; both are separate services of the same provider, also run on Cloudflare. Only the code is sent for the check. If you redeem a code from the partner programme, I also send your store address to the partner programme so that I can assign the partner’s commission; the partner receives no store address, name or contact details of your store, only totals and, for each store attributed to them, a sequential number with the month of first payment, the commission rate and the plan status (for example trial or paying). The waiting list does not learn which store redeemed its code.

Partner programme. For settling commission with partners, the partner programme (a separate service of the same provider, also run on Cloudflare) reads through the Shopify Partner API what Shopify reports to me as the app’s provider about every store that installs the app: events (installation, uninstall, subscription, cancellation, pause and decline of a subscription) and charges (amount, currency, time, id and interval of the subscription), each with the store address. If your store is not attributed to a partner, I delete its events after 14 days and its charges after 24 months. If it is attributed to a partner (through their code, their partner link or manually), I store the store address, plan status (for example trial, paying, uninstalled), charges and the commission calculated from them for as long as the attribution exists, that is also after an uninstall; records belonging to a self-billing invoice to the partner I keep for as long as tax law requires (up to 10 years, § 147 of the German Fiscal Code, AO). For attribution through a partner link I use the notice that Shopify sends to Google Analytics 4 of the App Store listing when a store installs the app from the App Store, and from it only the store address and the partner’s identifier; the recipient of this measurement data is Google Ireland Limited (Ireland), with processing also by Google LLC (USA) under the EU-US Data Privacy Framework. The partner receives no store address (paragraph “Codes”).

E-mail to you. Notices about your plan (the advance notice and the message that Free applies after your development store becomes a paid store) I send to the store e-mail address stored in your Shopify admin via Resend (Plus Five Five, Inc., 2261 Market Street #5039, San Francisco, CA 94114, USA). Resend is my processor under a contract pursuant to Art. 28 GDPR. Resend sends via servers in Ireland but stores recipient, subject, text and delivery logs in the USA and deletes them after 30 days, backups after a further 7 days. Resend is certified under the EU-US Data Privacy Framework (adequacy decision of the European Commission, Art. 45 GDPR); the EU standard contractual clauses (Art. 46 GDPR) apply in addition.

For internal operational alerts (for example “scan aborted”, “theme changed”) and for support I use Slack (Slack Technologies, LLC, USA, certified under the Data Privacy Framework). An operational alert contains your store address and a short event text, no images, no tokens. A support handover additionally contains your name and, if given, your e-mail address, your message text or an excerpt of it, the technical app state and, only if you explicitly entered it, the collaborator request code. The support channel is private and visible only to the support team.

Shopify itself is the source of your data and your own processor; the relationship between you and Shopify is governed by Shopify’s data processing agreement, not by this policy.

Legal bases

Use of the app, scan, storage of your decisions: performance of the usage agreement with you, Art. 6 (1) (b) GDPR.
Support chat, AI answer and handover to the support team: performance of the usage agreement with you (support), Art. 6 (1) (b) GDPR; if your staff write in the chat, legitimate interest in answering their requests, Art. 6 (1) (f) GDPR.
Plan status, billing through the Shopify entity and notices about your plan by e-mail: performance of the usage agreement with you, Art. 6 (1) (b) GDPR.
Redeeming a code, booking the benefit and the lock record “one code per store”: performance of the usage agreement with you (Section 7 (9) of the terms of use), Art. 6 (1) (b) GDPR; the lock record beyond uninstall and counting wrong entries: legitimate interest in enforcing the conditions of the codes, keeping a permanent discount for you also after a reinstallation and preventing abuse, Art. 6 (1) (f) GDPR.
Transmission of the store address to the partner programme: legitimate interest in settling the commission with the partner who gave you the code, Art. 6 (1) (f) GDPR.
Events and charges from the Shopify Partner API, attribution through Google Analytics 4 and storage for stores attributed to a partner: legitimate interest in attributing and settling commission with partners, Art. 6 (1) (f) GDPR; keeping records belonging to self-billing invoices: legal obligation, Art. 6 (1) (c) GDPR in conjunction with § 147 AO.
Read access to your store and storage of the collaborator request code: your consent, Art. 6 (1) (a) GDPR, withdrawable in the chat at any time; the withdrawal takes effect for the future.
Log entries, operational alerts, security checks, usage limit of the chat: legitimate interest in secure and traceable operation, Art. 6 (1) (f) GDPR.
Where you are a sole trader and your store address or e-mail refers to you personally, the same applies.

Two roles, kept apart: for the data I need to perform the agreement with you (store address, access token, log, settings), lakör is itself the controller. For image metadata and product data that I evaluate on your behalf, lakör is your processor. The agreement for this is part of the Terms of Use, annex “Data processing”, and is concluded with the installation.

What you do in the App Store (search, installation, reviews) is processed by the Shopify entity under its own privacy policy; I only receive the installation itself.

How long I store data

As long as Easy AI Act Image Labels is installed: everything in the table above.
After uninstall: Shopify invalidates the access token immediately, and I delete it on my side at the same moment. 48 hours later Shopify sends me the deletion command (shop/redact); then all data of your store is deleted. At the latest 30 days after uninstall all data is gone, even if the deletion command should not arrive; a daily clean-up run checks this.
Exception: log entries expire after 90 days, even if you uninstall earlier.
Exception lock record for a redeemed code: it does not contain your store address and expires after the period in the table above, regardless of an uninstall.
Exception partner programme: events and charges from the Shopify Partner API follow their own periods, regardless of an uninstall (14 days or 24 months without a partner; with a partner as long as the attribution exists, records belonging to self-billing invoices up to 10 years; paragraph “Partner programme”).
Support conversations expire 90 days after the last message, bug reports after 180 days, the collaborator request code after 14 days, the daily counters after 2 days, in each case also without uninstall; with the uninstall immediately.

Your rights

Access, rectification, erasure, restriction, data portability (Art. 15 to 20 GDPR): e-mail to support@easyaiactlabels.com, answer within 14 days, by law at the latest within one month.
Trigger deletion yourself: uninstall the app (Shopify admin, Apps, Easy AI Act Image Labels, Uninstall). Individual support requests you delete directly in the chat.
Withdraw consent (Art. 7 (3) GDPR): read access and collaborator request code you withdraw in the chat, without giving reasons.
Object to processing based on legitimate interest (Art. 21 GDPR): same address.
Complain to a data protection supervisory authority. Competent for me: Landesbeauftragter für Datenschutz und Informationsfreiheit Mecklenburg-Vorpommern (State Commissioner for Data Protection and Freedom of Information of Mecklenburg-Western Pomerania), Schwerin, Germany.

Visitors of these info pages

When you open these pages, Cloudflare as hosting provider processes technically necessary connection data (IP address, time, page requested, browser identifier) for delivery and to fend off attacks. I do not evaluate this data and use no cookies, no analytics tools and no external fonts on these pages.

Changes

If what I read, write, store or pass on changes, this policy is updated in the same step and the change is announced in the app. You will always find the current version at /en/privacy/; the legally binding German version is at /de/datenschutz/.

This website

This website is served via Cloudflare (Workers, Static Assets). It sets no cookies except the sign-in cookie in the partner area (see “Partner programme”), loads no fonts or scripts from third parties (fonts are served from the same server) and uses no analytics that could recognise you. Cloudflare processes the connection data needed to deliver the page and to fend off attacks (IP address, time, requested page); the legal basis is Art. 6(1)(f) GDPR. If you write to me (support@easyaiactlabels.com), I process your details to answer your request (Art. 6(1)(b) or (f) GDPR).

AI image checker: checking images

Images you select in the AI image checker are read by your browser on your device. They are transferred neither to me nor to third parties; the PDF report is also created on your device.

AI image checker: checking a store

If you enter a store address, my program EasyAIActLabelsBot fetches public information from that store (robots.txt, product and collection lists, home page, up to 3 product pages, up to 30 product images, each partially; details on the page EasyAIActLabelsBot). The result consists of numbers and the addresses of up to 30 checked product images on cdn.shopify.com, not the images themselves, and is stored for 10 minutes so that the same request does not burden the store again. Your browser loads the preview images directly from the Shopify CDN (cdn.shopify.com); as with any image request, Shopify receives your IP address, but not the address of this page. I only use your IP address to limit the number of requests per minute (protection against misuse); it does not appear in any log. The logs contain the store domain, result and duration and are deleted after 7 days. The legal basis is Art. 6(1)(f) GDPR (providing the tool, protection against misuse).

AI image checker: confirming ownership and report

If you want a report on your store as its owner, I read the contact addresses published in the store (legal notice, contact page, footer) and show them to you only masked; they are not stored. I send an email with a confirmation link, valid for 24 hours, to the address you choose or enter as an address at your store domain. Only the click creates the report. For it, I read up to 1,000 product images of your store (the first 512 KB each) and store the numbers and up to 30 images in detail (file name, image address, product title, provenance data read) for 7 days. The report can only be reached through the link in my email; you can delete it earlier. Your browser loads the images in the report directly from the Shopify CDN (cdn.shopify.com); Shopify receives your IP address in the process. I only store the email address until the “report ready” email has been sent, then I delete it (how long the email service keeps emails is described in the next paragraph). I count how many confirmation emails were sent per store and day for 2 days, without addresses. The legal basis is Art. 6(1)(b) GDPR (you request the report) and, for the counters, Art. 6(1)(f) GDPR (protection against misuse).

Shopify AI Image Index

For statistics on the labelling of AI images in online retail, my program EasyAIActLabelsBot reads, at most once per edition, public information from Shopify stores on a public list of popular websites (Tranco) with the country ending of an EU member state, .eu or .ch: the same pages and image beginnings as in the store check, details on the EasyAIActLabelsBot page. Only totals across at least 50 stores are published, never individual stores. The list of addresses read and the individual results stay internal and are deleted after 15 months at the latest. If a store address names a person, it is personal data; the legal basis is then Art. 6(1)(f) GDPR (statistics on AI labelling, Art. 89(1) GDPR). You can object: by email to the address in the legal notice or by blocking EasyAIActLabelsBot in your robots.txt; I then delete the information about your store and exclude it from future surveys.

Sending emails

I send the emails via Resend (Plus Five Five, Inc., San Francisco, USA) as a processor. Resend sends them via servers in Ireland, but stores recipient, subject, content and delivery logs in the USA and deletes them after 30 days, backups after a further 7 days. Resend is certified under the EU-US Data Privacy Framework (adequacy decision of the European Commission of 10 July 2023); EU standard contractual clauses apply in addition. The emails contain no tracking pixels and no rewritten links; open and click tracking is switched off.

News on AI labelling (optional)

If you tick the second box when confirming, I will occasionally send you news on labelling AI images to the confirmed address. The legal basis is your consent (Art. 6(1)(a) GDPR), which you give by clicking the confirmation link. As proof I store the address, store domain, time of the request and of the confirmation, language and the version of the consent text. You can unsubscribe at any time via the link in each of these emails; I will then send nothing more and keep the proof only blocked, as evidence of the earlier consent, for at most 3 years (Art. 6(1)(f) GDPR, defence against claims).

Partner programme

This section applies if you sign up as a partner or are a partner (partner terms). The controller is the provider named at the top of this policy. Questions about the partner programme and your data: partners@easyaiactlabels.com.

What I process. When you sign up: your e-mail address, your language, your confirmation that you are acting as a business and the version of the partner terms you accept, each with a timestamp. I need nothing more for the sign-up. Later, at the latest when your balance reaches 50 EUR, you enter in your account: name, company, address with country, your VAT status with VAT ID, tax number or tax or registration number, and your PayPal address (required details for self-billing invoices and payouts). Voluntarily, you can enter where you recommend the app and, for the community benefit, the number of followers or subscribers of one channel with the public link to that channel; if at my request you send me evidence of it (for example an extract from the channel’s statistics), I process that as well. I also process: your partner code and an earlier code if you changed it, which stores are attributed to you (per store the month of first payment, commission rate and plan status), commission, self-billing invoices and payouts, the date on which your balance reached 50 EUR with the related reminders, whether and when I confirmed or did not confirm your community details, notes on spot checks of your advertising, the result of the check of your VAT ID and a log of changes to your payout and tax details. If you applied under an earlier version of the partner terms with the form used at the time, I additionally process the details from it (website, type of business, your channels, whether you are looking for a cooperation, your message). I need the required details for the self-billing invoices and the payout; without them I cannot settle (partner terms, Section 8 (3)).

Purposes and legal bases.

Running the partnership, your account, code and link, attribution, commission, self-billing invoices, payouts, checking your community details and the related e-mails (sign-up confirmation link, welcome with code and link, sign-in link, monthly report, reminders about missing details, final settlement, termination): contract, Art. 6(1)(b) GDPR.
Issuing and keeping self-billing invoices, checking VAT IDs: legal obligation, Art. 6(1)(c) GDPR in conjunction with §§ 14, 14a and 14b of the German VAT Act (UStG) and § 147 of the German Fiscal Code (AO).
Protection against abuse (limiting sign-ups per IP address, without storing the IP address), the block list of earlier codes, the change log, internal notification, spot checks of advertising under the partner terms, defence against claims: legitimate interest in a secure and traceable partner programme, Art. 6(1)(f) GDPR.

There is no automated decision within the meaning of Art. 22 GDPR based on an evaluation of your person. Account, code and link are created when you confirm your sign-up, without a review; a human decides on the community benefit, spot checks and terminations.

Sign-in and cookie. You sign in to your partner account with a link I send you by e-mail; it is valid for 20 minutes and only once. I then set the cookie “eal_p”, which keeps you signed in for 30 days. It is valid only for the partner area, cannot be read by scripts and is strictly necessary so that you can use the account you expressly requested (§ 25(2) no. 2 of the German Telecommunications Digital Services Data Protection Act, TDDDG). I only keep a check value (hash) of link and cookie from which they cannot be recovered. When you sign out, I delete the cookie. The partner area sets no other cookies; I set none for the partner link either.

Attribution of installations. If a store installs the app through a partner link, Shopify reports the installation event with the store address and the partner identifier (part of the link) to the Google Analytics 4 of the app listing. I read the reports daily and attribute the store to the partner; for this I use only the store address and the identifier. The recipient of the measurement data is Google Ireland Limited (Ireland), with processing also by Google LLC (USA) under the EU-US Data Privacy Framework. Basis: Art. 6(1)(f) GDPR (attribution and settlement of commissions), for you as a partner also point (b) (performance of the contract).

Status of attributed stores. For settlement and for the display in the partner account I read from the Shopify Partner API the app’s bills and its events (installation, uninstallation, subscription, cancellation, pause and decline of a subscription, each with time and store address). For stores attributed to a partner I derive from them the plan status (Free, trial, paying, paused, uninstalled) and the month of first payment. Events of stores not yet attributed to a partner I keep for at most 14 days, so that a later attribution (for example by code) shows the correct status; after that I delete them. The partner sees no store address, only a sequential number per store with month of first payment, commission rate and plan status. Basis: Art. 6(1)(f) GDPR (settlement of commissions), for you as a partner also point (b).

Recipients.

Cloudflare, Inc. (USA) runs the platform and the database of the partner programme as my processor, as described under “Where your data is located”.
Resend sends the partner programme e-mails (sender partners@easyaiactlabels.com) as my processor, as described under “Sending emails”.
PayPal (PayPal (Europe) S.à r.l. et Cie, S.C.A., Luxembourg) receives your PayPal address, the amount and the invoice number for each payout. PayPal is a separate controller for the payment; PayPal’s privacy statement applies.
Slack (Slack Technologies, LLC, USA): for a new sign-up I receive an internal message with your partner number, the domain of your e-mail address and your language; for your first attributed store, with the places you voluntarily gave for your advertising; and for community details, with the number and link of your channel. These messages contain no tax or payout details. For an application under the earlier version, the message contained your name and company. Messages about the monthly run contain totals only. Slack is my processor.
European Commission (VIES): if your registered office is in another EU member state, I check your VAT ID in the European Commission’s confirmation service when you enter it and before every self-billing invoice; the query is answered by the tax administration of your country.
Tax advisers and tax authorities receive self-billing invoices and accounting data as far as accounting and tax law require.

Transfers to the USA. Cloudflare, Resend and Slack also process data in the USA. The transfer is based on these providers’ certification under the EU-US Data Privacy Framework (adequacy decision of the European Commission of 10 July 2023, Art. 45 GDPR) and, where agreed, additionally on EU standard contractual clauses (Art. 46 GDPR).

How long I keep data.

Applications under the earlier version that I declined: 6 months after the decision.
Sign-in links: until used, at most 20 minutes. Sessions: 30 days or until you sign out.
Unconfirmed sign-ups: 24 hours; after that I delete the e-mail address, language and confirmations.
Accounts without an attributed store and without commission that you have not signed in to for 24 months: I delete them; I tell you by e-mail 30 days beforehand, and if you sign in, the account stays.
During the partnership: everything I need for it. Community details and evidence that you change are replaced by the new ones.
After the partnership has ended: details I do not need for self-billing invoices, payouts and their documentation (for example website, channels, type of business, message, places of your advertising, community details) are deleted as soon as the last self-billing invoice has been paid out or a balance below 50 EUR has been forfeited and no run-off period is running any more.
Events of stores not attributed to a partner: at most 14 days.
Self-billing invoices (PDF and XML), payouts, the revenue data they are based on, the master data needed for them (name, address, e-mail address, tax details, PayPal address) and the log of changes to payout and tax details: 8 years from the end of the calendar year in which the invoice was issued (§ 147(1) no. 4 and (3) AO, § 14b(1) UStG); longer only while they are relevant for a tax assessment that is still open. Until then you can sign in and download your invoices.
Slack messages about sign-ups, applications and community details: at most one year.
E-mails at the sending service: as described under “Sending emails”.

Your rights. The rights under “Your rights” apply (access, rectification, erasure, restriction, data portability, objection, complaint to a supervisory authority). For the partner programme you can also reach me at partners@easyaiactlabels.com. You change your name, address, tax, payout and community details yourself in your account.

This is a courtesy translation. The German version is the binding one: Deutsche Fassung.