Privacy & Data Processing Notice

Who we are

DigieSales Ltd. is a company incorporated under the laws of The Commonwealth of The Bahamas with its registered office in Nassau, New Providence. For data-protection purposes our Data Protection Officer can be reached at dpo@digiesales.ai.

Controller vs. processor roles

We act in two distinct capacities:

• Controller — for the information you give us directly to set up and manage your DigieSales account (your name, business name, email, billing details, support correspondence). We decide the purposes and means of that processing.
• Processor — for the data about your end-customers and your store that the Service ingests in order to deliver features (orders, carts, customer profiles, browsing events, etc.). You are the controller; we process this data only on your documented instructions, which are embodied in your configuration of the Service and these Terms.

Where the GDPR, UK GDPR, or analogous laws apply, this Notice together with our Terms constitutes the written Data Processing Agreement ("DPA") between you and DigieSales. A standalone DPA with the Standard Contractual Clauses is available on request from dpo@digiesales.ai.

What data we collect

We collect only what we need to run the Service. Below is the canonical inventory; if a feature is disabled in your dashboard, the corresponding data is not collected.

We do not knowingly collect special-category personal data (health, biometric, racial, religious, sexual-orientation, trade-union) and you must not transmit such data through the Service without a signed addendum.

How we use that data

We use the data described above for the following purposes only:

• To provide the Service — running plugin features (cart recovery, segmentation, price alerts, etc.), displaying analytics in your dashboard, generating AI-drafted emails and copy when you enable those features.
• To bill you — managing subscriptions, processing payments via Stripe, issuing invoices.
• To support you — responding to tickets, diagnosing issues, communicating about service outages and material changes.
• To secure the Service — fraud and abuse detection, rate-limiting, intrusion detection, license-key validation.
• To improve the Service — aggregated, de-identified usage analytics (e.g., "how many stores use feature X"). Aggregated data cannot be re-associated with any individual or store.
• To comply with the law — meeting tax, accounting, and regulator obligations applicable to DigieSales.

We will not use your data for any other purpose without first obtaining your additional consent.

AI & automated analysis

Specifically:

• AI sub-processors (OpenAI, Anthropic, Google Cloud Vertex AI) operate under their enterprise/API terms which explicitly prohibit the use of API inputs and outputs to train their general-purpose models. We have selected these vendors for this reason and we audit the terms annually.
• Where DigieSales fine-tunes a model on your tenant's data to improve quality for your store (for example, learning your brand voice), that fine-tuned model is isolated to your tenant. It is not shared with any other customer and is destroyed when your account is deleted.
• Aggregate usage statistics derived from AI features (e.g., "the segmentation feature was called 1.2M times this month") may be retained in a non-identifiable form for capacity planning.
• You can disable AI-powered features at any time from Dashboard → AI Usage. The Service remains functional without them at reduced capability.
• No DigieSales feature makes a "solely automated decision producing legal or similarly significant effects" on an individual within the meaning of GDPR Article 22. All customer-facing outputs (emails, prices, recommendations) require human approval by you, the store operator, before being sent or applied.

No sale, no sharing, no brokering

The only situations in which we disclose data to a third party are listed in Section 7 (Sub-processors) and Section 14 (Government requests).

Sub-processor register

We rely on the following sub-processors to operate the Service. Each is bound by a written agreement requiring data-protection obligations no less stringent than those in this Notice, and each is restricted to processing data only on our documented instructions.

We will give you at least thirty (30) days' notice — by email and via your dashboard — before adding or replacing a sub-processor. You may object to a new sub-processor within fifteen (15) days; if we cannot accommodate your objection, your sole remedy is to terminate your subscription and receive a pro-rata refund for the unused portion of a prepaid term.

Hosting & international transfers

Your data is hosted in the AWS region most appropriate to your account's billing region: by default in us-east-2 (Ohio) for customers billed in USD/CAD, and eu-central-1 (Frankfurt) for customers billed in EUR/GBP. Enterprise customers may request an alternate region in writing.

Where personal data is transferred from the European Economic Area, the United Kingdom, or Switzerland to a country not deemed adequate by the relevant authority, we rely on the European Commission's Standard Contractual Clauses (2021/914) and the UK Addendum (B.1.0), together with supplementary technical measures (encryption in transit and at rest, key-management isolation, sub-processor flow-down).

Security measures

We implement organisational and technical safeguards appropriate to the sensitivity of the data, including:

• TLS 1.2+ for all data in transit; HSTS preload; modern cipher suites only.
• AES-256 encryption at rest for databases, backups, and object storage; envelope encryption with AWS KMS.
• Role-based access control with least-privilege; mandatory hardware-key two-factor authentication for all staff with production access; quarterly access reviews.
• Network segmentation between application, database, and AI-inference tiers; private VPC with no public ingress to the database tier.
• Audit logging of all administrative actions (90-day hot retention, 1-year cold retention).
• Annual third-party penetration test; continuous vulnerability scanning; bug-bounty program (security@digiesales.ai).
• SOC 2 Type II audit (in progress for 2026); ISO/IEC 27001 alignment.
• Background checks on all engineering staff; written confidentiality and acceptable-use policies; offboarding within 24 hours of separation.

Retention & deletion

You can request earlier deletion of personal data at any time under Section 11.

Your rights

Depending on where you live, you and your end-customers have the right to:

• Access — receive a copy of personal data we hold about you.
• Rectify — correct inaccurate or incomplete data.
• Erase — request deletion ("right to be forgotten"), subject to lawful retention obligations.
• Restrict or object — to certain processing, including direct marketing.
• Portability — receive your data in a structured, machine-readable format.
• Opt out of sale or sharing (CCPA/CPRA) — DigieSales does not sell or share data, so this is satisfied by default. You may still submit a "Do Not Sell or Share" request to confirm.
• Lodge a complaint with your local data-protection authority (in the EU/UK), the California Attorney General, or the Bahamas Data Protection Commissioner.

To exercise any right, email dpo@digiesales.ai. We will respond within thirty (30) days. If you are an end-customer of a DigieSales merchant, please contact the merchant first — they are the controller of your data; we will redirect requests to them where appropriate.

Cookies & tracking

The DigieSales marketing website (digiesales.ai) uses only strictly-necessary first-party cookies for session management and CSRF protection, plus self-hosted, IP-anonymised analytics (Plausible). We do not use Google Analytics, Facebook Pixel, or any cross-site advertising trackers on our own properties.

Cart-recovery and analytics features installed on your store may set a first-party cookie on the customer's browser to identify carts across sessions. The cookie contains an opaque session token only — no email, no PII, no third-party identifiers. You are responsible for disclosing this in your own store privacy policy and obtaining consent where required.

Children's data

The Service is not directed to children under sixteen (16) years of age, and we do not knowingly collect personal data from children. If we become aware that we have processed such data without verified parental consent, we will delete it without undue delay. Merchants who knowingly target children must not use the Service.

Government & law-enforcement requests

We respect lawful, narrowly-scoped legal process directed at DigieSales. Our policy is to:

• Require valid legal process (subpoena, court order, MLAT request) — informal requests are refused.
• Notify the affected customer before disclosure, unless doing so is legally prohibited (in which case we will notify as soon as the prohibition lifts).
• Challenge requests that are overbroad, unlawful, or made by an agency without jurisdiction over DigieSales in The Bahamas.
• Publish an annual transparency report counting the number of requests received, granted, and refused.

Data-breach notification

If we become aware of a personal-data breach that is likely to result in a risk to the rights and freedoms of natural persons, we will notify affected customers without undue delay and in any case within seventy-two (72) hours of becoming aware. The notification will describe the nature of the breach, the categories and approximate number of records affected, the likely consequences, and the measures taken or proposed to mitigate harm.

Governing law

Changes to this notice

We may update this Notice from time to time. Material changes will be notified to you by email and posted in your dashboard at least thirty (30) days before they take effect. The "Effective" date at the top of this page indicates when the current version became effective. Previous versions are available on request from dpo@digiesales.ai.

Contact & Data Protection Officer

To exercise any right under this Notice, to file a complaint, or to ask any question about how we handle data, please use the contact details below.