Effective date:** 17 July 2026

CheckoutControl (the App) is provided by Péter Kiss, a self-employed sole
trader (autónomo) established in Spain, trading as 8DIGITS Digital Marketing
(we, uso our). This policy explains how the App
processes information when a Shopify merchant installs or uses CheckoutControl.

1. Who is responsible

Provider: Péter Kiss, self-employed sole trader (autónomo)
Registered address: Calle Las Huertas 15, Frigiliana, 27988 Málaga, Spain
Registration and tax number: ESZ0486396C
Privacy contact: support@8digits.es
DPO or representative: A separate Data Protection Officer or EU/UK
representative has not been appointed because the owner determined that one is
not required for the current processing. Péter Kiss remains the privacy contact.

For personal information about a merchant’s buyers, the merchant generally
decides why CheckoutControl is used and should be the buyer’s first contact.
We act as an independent controller for merchant account details, support
correspondence, security logs, billing records, and our own legal compliance.
When CheckoutControl processes merchant buyer data solely to provide the App
under the merchant’s instructions, we act as the merchant’s processor or
service provider. Shopify executes the Functions described below, and the
current App does not persist their buyer/cart input in its application database.

2. Information CheckoutControl processes

Merchant and app-user information

When a merchant installs or uses the App, Shopify can provide and the App can
store:

Buyer and cart information processed by Shopify Functions

To evaluate the merchant’s rules during a cart or checkout, CheckoutControl’s
Shopify Functions can transiently process the minimum fields needed for the
configured rules:

The current Function inputs do not request a buyer’s customer ID, name,
email address, phone number, or order history. CheckoutControl does not persist
the Function’s buyer/cart input in its application database. Shopify executes
the Functions and applies their returned payment, delivery, or cart-transform
operations.

Cart-page selector

When enabled by the merchant, the theme app block writes _cod_selected as a
Shopify cart attribute through Shopify’s cart API. The App’s current source does
not add advertising, marketing, or behavioral-analytics trackers to the
storefront. Shopify and the merchant’s theme or other apps may independently
use cookies or similar technologies under their own policies.

Support and operational information

If a merchant contacts support, we receive the information they choose to send,
such as contact details, store domain, screenshots, and troubleshooting details.
Do not send access tokens, passwords, payment-card data, or unnecessary buyer
information.

The App creates limited operational logs containing events such as shop domain,
webhook topic, Function registration or configuration status, payload size, and
error details. Compliance-webhook payload bodies and their customer or order
identifiers are not intentionally logged by the current source.

3. How information is used

We use information to:

For controller-side processing, we rely on performance of the merchant contract
where Article 6(1)(b) GDPR applies; our legitimate interests under Article
6(1)(f) in operating, securing, supporting, debugging, preventing abuse, and
improving the App’s reliability; and Article 6(1)(c) legal obligations for tax,
accounting, regulatory, privacy, and lawful-request compliance. Where a future
optional purpose requires consent, we will request it before that processing.
The current source has no advertising or behavioral-analytics purpose.

We do not use buyer information for advertising, data-broker activity, or
independent profiling. We do not sell or share personal information as those
terms are defined by the California Consumer Privacy Act.

4. Service providers and disclosures

CheckoutControl depends on:

Shopify’s privacy terms and Data Processing Addendum are available at
https://www.shopify.com/legal/privacy and https://www.shopify.com/legal/dpa.
Railway’s privacy policy, terms, and Data Processing Addendum are available at
https://railway.com/legal/privacy, https://railway.com/legal/terms, and
https://railway.com/legal/dpa. The current source uses no other runtime
subprocessors.

We can also disclose information when required by law, to protect rights or
security, in connection with a business transaction, or with the merchant’s
instructions. We require service providers to process information only for the
agreed services and subject to appropriate safeguards.

5. International transfers and hosting location

The App is operated from Spain. Railway stores and processes the production
application and PostgreSQL database in the EU. Shopify and Railway may process
information in other locations as described in their applicable terms and
DPAs. Where required, international transfers are protected through applicable
adequacy mechanisms, standard contractual clauses, or other lawful safeguards.

6. Retention and deletion

Shopify requires App Store apps to act on valid privacy requests within 30 days,
subject to lawful retention exceptions.

7. Privacy requests and choices

Depending on applicable law, an individual may have rights to access, correct,
delete, restrict, object to, or receive a portable copy of personal information,
and to complain to a data-protection authority.

Buyers should normally submit requests to the Shopify merchant that operates the
store. Merchants and other individuals can contact support@8digits.es. We may need
to verify the request and coordinate with the relevant merchant and Shopify.
The App is subscribed to Shopify’s mandatory customers/data_request,
customers/redacty shop/redact compliance webhooks.

Péter Kiss records each request and its deadline, verifies the requester using
the least additional information reasonably necessary, identifies the relevant
merchant and responsible party, coordinates with the merchant and Shopify,
searches applicable app, session, support, and operational records, and carries
out the applicable access, correction, export, restriction, or deletion. We
respond within 30 days unless applicable law permits an extension. Backups age
out under the retention schedule above, and a minimal response record is kept
under the support-record schedule.

8. Security

The current App uses Shopify OAuth, Shopify’s webhook authentication, encrypted
HTTPS connections, restricted OAuth scopes, and access-controlled production
services. Railway provides encryption at rest, managed backups, access controls,
access reviews, incident-response procedures, and secret-rotation controls for
the production application and PostgreSQL database. No internet service is
completely secure.

9. Changes to this policy

We may update this policy when CheckoutControl, our providers, or legal
requirements change. We will post the revised policy at
https://8digits.es/checkoutcontrol-privacy-policy/ and update the effective
date. Where required, we will provide additional notice.

10. Contact

Questions or privacy requests can be sent to:

Péter Kiss, trading as 8DIGITS Digital Marketing
Calle Las Huertas 15, Frigiliana, 27988 Málaga, Spain
support@8digits.es

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