The contract governing the processing of personal data between your store and BOUCLR. It follows the mandatory clauses of Article 28(3) GDPR and the European Commission's standard contractual clauses (Implementing Decision (EU) 2021/915).
You, the merchant, are the controller: it is your data, and you decide why it is processed.
IKKI'S DIGITAL OÜ, a company incorporated under Estonian law and the publisher of BOUCLR, is the processor: it processes that data on your behalf, on your instructions, and for nothing else.
Both parties are established in the European Union. The applicable law is Union law, supplemented by Estonian law.
As IKKI'S DIGITAL OÜ has its main establishment in Estonia, its lead supervisory authority within the meaning of Article 56 GDPR is the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon), Tatari 39, 10134 Tallinn. You keep the right to lodge a complaint with the supervisory authority of your own country.
| Subject matter | Providing the Product Assistant: showing messages on your product pages, answering your visitors' questions, and measuring the orders that follow. |
|---|---|
| Duration | For as long as the app is installed, then the retention periods below. |
| Nature | Collection, recording, consultation, erasure. |
| Data subjects | Visitors to and customers of your store. |
| Data | A technical visitor identifier, the timestamp, the message shown or the question asked, the amount and the order number. No name, no email address, no phone number, no postal address, no payment method. |
| Special categories | None. The app processes no health data, no biometric data, and no other category listed in Article 9 GDPR. |
In accordance with Article 28(3) GDPR, IKKI'S DIGITAL OÜ undertakes to:
If an instruction you give appears to us to infringe Union or Member State law, we inform you immediately.
Union law requires a period that is necessary and justified, without ever setting a number: that is Article 5(1)(e) GDPR, confirmed by the guidance of the European Data Protection Board. The period is therefore set by the product's actual use:
Both periods are applied automatically: beyond them, records are erased with no intervention, and that erasure is verified by a test suite. They come on top of the immediate erasures set out in the privacy policy (uninstall, shop deletion request, customer request).
We review them every year: a period justified today is not justified indefinitely.
You give general authorisation to the sub-processors listed below. Any addition or replacement is notified to you at least 30 days in advance, on this page and by email. You may object during that period; failing agreement, you may terminate at no cost.
| Sub-processor | Role | Location |
|---|---|---|
| Hetzner Online GmbH | Hosting of the service and the database | Nuremberg, Germany · European Union |
| Anthropic | Language model, for answers to open questions | United States |
Anthropic is the only transfer outside the Union. It is covered by the European Commission's standard contractual clauses. Only the question asked and the store information needed for the answer are sent: no customer record, no visitor identifier. If a visitor writes an email address or a phone number into their own question, it is replaced before anything is stored.
No other third party is contacted from your store: neither the assistant nor the order counter reaches anything other than our own service.
In the event of a personal data breach we inform you without undue delay and at the latest within 48 hours of becoming aware of it, stating the nature of the breach, the categories and approximate number of data subjects, the likely consequences and the measures taken. You notify the supervisory authority, and the data subjects where required · we give you everything you need to do so.
You may request, once a year and with reasonable notice, the information demonstrating compliance with this agreement. An on-site audit remains possible where justified, at the requesting party's expense, and without compromising the confidentiality of other merchants.
When the app is uninstalled, or at your request, the data is erased or returned at your choice, copies included, save for any legal retention obligation. Erasure is immediate and verifiable.
This agreement applies from the moment the app is installed on your store. Any change is notified to you 30 days before it takes effect.
For any question, or to receive a signed copy: support@bouclr.com.