Privacy Policy

ΠΙΡΣΕΛ Ι.Κ.Ε. ("PIRCEL P.C.")

A private company incorporated under the laws of the Hellenic Republic

Registered office: 32 Voukourestiou Street, 106 71 Athens, Greece

General Commercial Registry (G.E.MI.) No.: 165318701000

VAT No.: EL801893971

Competent Tax Office: Athens D'

Privacy contact: privacy@pircel.com

General contact: contact@pircel.com

We have not appointed a formal Data Protection Officer (DPO) as we are not required to under Article 37 GDPR, but you can contact us about any privacy matter at the email address above.

Pircel operates in two distinct capacities with respect to personal data:

2.1 As a Data Controller

We determine the purposes and means of processing for:

• Visitors to the Website and recipients of our marketing communications;
• Prospective customers who submit inquiries through our contact form, book demos, or otherwise interact with our sales process;
• Authorized users of our customers (e.g., employees and contractors of our Merchant customers who log into the Service); and
• Our own employees, suppliers, and other counterparties.

This Privacy Policy describes how we process personal data in our role as Controller.

2.2 As a Data Processor

We process personal data on behalf of our Merchant customers (each a Customer) who use the Service to manage their shipping operations. This includes the personal data of natural persons to whom Customers ship parcels (End Recipients). For this processing, the Customer is the Data Controller and Pircel is the Data Processor. Our processing of such data is governed by the Data Processing Agreement entered into with each Customer.

End Recipients seeking to exercise data subject rights in respect of their shipment-related data should contact the Merchant that arranged the shipment. We will assist Merchants in fulfilling such requests in accordance with our Data Processing Agreements.

3.1 From Website Visitors

When you visit the Website, we (and our service providers acting on our behalf) automatically collect:

• Technical and device data: IP address, browser type and version, operating system, language settings, screen resolution, device identifiers, and referring URL.
• Usage data: pages viewed, time spent on pages, clicks, navigation paths, and timestamps.
• Diagnostic data: error reports, performance metrics, and (where applicable) interaction recordings captured for debugging purposes (see Section 5 on Session Replay).
• Cookie and tracker data: as described in our Cookie Policy.

Usage data, and the performance traces and session replays recorded in your browser, are collected only after you accept analytics in our cookie banner. Error reports without session replay are collected without it, as strictly necessary to keep the Website and the Service working (Section 5.1).

3.2 From Prospective Customers (Contact Form, Demo Bookings)

When you submit the contact form on the Website or contact us by email:

• Identification data: full name.
• Contact data: email address; phone number (if provided).
• Content of inquiry: the message you write and any other information you choose to provide.

When you book a demo via our scheduling tool (Cal.com):

• Data you provide to that tool (typically name, email, and chosen time slot). Cal.com is the data controller for the booking process; please refer to Cal.com's privacy policy. We receive the booking confirmation and details.

3.3 From Customers and Their Authorized Users

When you (or your colleagues) register for and use the Service:

• Account data: full name, email address, hashed/derived authentication material (we use one-time passcodes and signed tokens; we do not store account passwords).
• Profile data: role within your organization, eshop name, configuration preferences.
• Authentication metadata: session timestamps, IP addresses associated with sign-ins, and security events (e.g., login attempts, OTP requests).
• Service usage data: actions taken within the dashboard, features used, support inquiries, and audit-log entries.
• Billing data (where applicable): commercial terms are agreed at the Customer level; if billing data is collected, the details are set out in the applicable Customer Agreement.

3.4 From or About End Recipients (Processed on Behalf of Our Customers)

When a Customer uses the Service to arrange a shipment, the Customer submits (or causes to be submitted) personal data about the End Recipient. This data is processed by Pircel on the Customer's behalf as a Processor. It includes:

• Identification data: recipient full name; sender full name.
• Contact data: recipient postal address (street, city, postcode, country), phone number, and (where provided) email address.
• Shipment data: order reference, parcel dimensions and weight, cash-on-delivery (COD) amount, delivery notes, and any other information necessary to fulfil the shipment.
• Document data: where applicable, customs documents, invoices, or other shipping-related documents containing personal data (e.g., recipient identity for customs purposes).
• Tracking data: shipment status updates received from Carriers and made available via the Service and the tracking widget.

For details on how we handle this data as a Processor, please see the Data Processing Agreement entered into with the relevant Customer.

We process personal data for the following purposes, relying on the legal bases identified below in accordance with Article 6 GDPR.

You may withdraw consent at any time, without affecting the lawfulness of processing carried out before withdrawal.

5.1 Error Monitoring and Session Replay (Sentry)

We use Sentry (Functional Software, Inc.; Sentry's EU data region in Frankfurt, Germany) to capture errors in the Service, the Pircel API and the dashboard. Error reports carry the error, the page's address and technical details of the browser, configured to exclude personal data values; without session replay, they're sent without consent, as strictly necessary to keep the Service working. Performance traces and session replays in your browser run only after you accept analytics in our cookie banner. Replays show no page text or inputs, and block images and media. Error reports and replays are kept up to 90 days and accessed only by authorised engineers.

5.2 Product Analytics (PostHog)

We use PostHog (PostHog, Inc., a US company; processing may take place in the United States and elsewhere, under Standard Contractual Clauses) to understand how the Service is used, only after you accept analytics in our cookie banner. For authenticated users, we associate analytics events with the user's account identifier, email address, full name, and eshop identifier so that we can analyze usage at the level of individual organizations and accounts. This is described in PostHog's privacy policy at posthog.com/privacy. You can withdraw your consent at any time from "Cookie preferences", in the Website's footer or the dashboard's account menu.

5.3 Session Replay (PostHog, where enabled)

Where enabled, and only after you accept analytics, PostHog Session Replay records playback of user interactions within the Service to help us understand user behavior and diagnose usability issues. The page's text and inputs are masked, so recordings show neither.

5.4 Carrier-Invoice OCR (Mistral AI)

When a Customer uploads carrier invoices for reconciliation purposes, the invoice files (which may contain End Recipient names, addresses, voucher codes, COD amounts, and other shipment details) are transmitted to Mistral AI (Mistral AI SAS, France) for optical character recognition and structured extraction. Mistral acts as our sub-processor and processes the data on our documented instructions. It keeps nothing after reading an invoice (zero data retention) and doesn't train on it. Mistral doesn't commit to a location for the requests Pircel sends to its global endpoint, api.mistral.ai. Transfers outside the EEA follow Mistral's Data Processing Addendum: an adequacy decision, other appropriate safeguards, or Standard Contractual Clauses.

5.5 Address Checks (Google Maps Platform)

We use the Google Maps Platform (Google LLC), its Geocoding, Address Validation and Places APIs, to check, standardise and look up postal addresses, from Pircel's servers. For a booking, the street line, town, county, postcode and country are sent; for a rate quote, only the postcode, town, region and country; for an address lookup, the address text entered. Google receives them as an independent controller under its Maps Platform terms (Section 7.2), and its processing is governed by its own privacy policy, available at policies.google.com/privacy. The map coordinates Google returns are kept with the recipient's other details, for that shipment only, and deleted with them.

5.6 Transactional Email and Contact Form (Mailgun, Google Workspace)

When you submit our contact form, your name, email address, and message are transmitted to Mailgun (Mailgun Technologies, Inc., EU region — api.eu.mailgun.net) for delivery to our team's mailbox, hosted on Google Workspace (see Section 7.1). We also use Mailgun to send transactional emails to Customers and End Recipients (e.g., shipment status notifications) where instructed by the relevant Merchant.

5.7 Website and Dashboard Hosting (Vercel)

The Website and the dashboard are hosted on Vercel (Vercel, Inc.). Personal data processed by Vercel for our deployments, including recipient data shown in the dashboard, is processed in the EU (Paris), and Vercel's backups replicate globally. The transfer relies on Vercel, Inc.'s certification under the EU–US Data Privacy Framework.

5.8 Backend Infrastructure

The Service's backend application and database run on infrastructure provided by third-party hosting and storage providers (currently Heroku/Salesforce, MongoDB Atlas, Redis Cloud, and Amazon Web Services), and personal data processed by the Service is processed in the EU. Service logs are kept by SolarWinds (Papertrail) in the United States, holding identifiers only, under Standard Contractual Clauses (Module Three) with a transfer impact assessment. Each provider's location and transfer safeguard is listed at /subprocessors.

5.9 No Automated Decision-Making with Legal or Similarly Significant Effects

We do not carry out automated decision-making that produces legal effects concerning you or similarly significantly affects you within the meaning of Article 22 GDPR. The automated processing we perform (e.g., OCR of invoices, address canonicalization, analytics aggregation) is operational in nature and does not result in decisions of that kind.

We collect personal data:

• Directly from you, when you interact with the Website, submit the contact form, request a demo, sign up for the Service, sign in, or otherwise communicate with us;
• From our Customers, when they use the Service to arrange shipments (including data about End Recipients);
• Automatically, through cookies and similar technologies as described in our Cookie Policy;
• From third parties, including Carriers (for shipment-tracking updates), e-commerce platforms connected by Customers (for order synchronization), and publicly available sources (where lawful).

We disclose personal data to the following categories of recipients, only as necessary for the purposes described above:

7.1 Sub-processors

Third-party service providers that process personal data on our documented instructions to deliver the Website and the Service (including hosting, databases, error monitoring, analytics, transactional email, service logs, OCR, and similar services). A current list of our sub-processors, including their location and the categories of data they process, is published at /subprocessors and is updated when changes occur. Each sub-processor is bound by a contract that meets the requirements of Article 28 GDPR.

7.2 Third-Party Recipients (Independent Data Controllers)

Certain third parties receive personal data not as our sub-processors, but as independent data controllers acting in their own right:

• Carriers (currently including ACS, BCS, BoxNow, DHL, FedEx, Geniki Taxydromiki, Speedex, TCS, and UPS). When a shipment is created, the End Recipient's name, address, phone number, and (where applicable) email address and shipment details are transmitted to the chosen Carrier to enable delivery. Each Carrier acts as an independent data controller in respect of that data and is subject to its own privacy notice and obligations.
• E-commerce platforms (Shopify, WooCommerce, Magento, PrestaShop) — where a Customer connects their e-commerce store, data is exchanged between that store and the Service. The merchant's store is operated by the Customer and/or the platform provider as a separate controller.
• Google LLC (Google Maps Platform: the Geocoding, Address Validation and Places APIs), for address checks and lookups: an independent controller under its Maps Platform terms (EEA Terms of Service §4.5; Controller-Controller Data Protection Terms §4.1(a)), on its own Data Privacy Framework certification and the Standard Contractual Clauses in its controller terms (Section 5.5).
• Cal.com (scheduling), for demo bookings you initiate via the booking link.

7.3 Professional Advisors, Authorities, and Successors

We may disclose personal data to our auditors, lawyers, accountants, insurers, and other professional advisors; to public authorities, courts, or regulators where required by law or to establish, exercise, or defend legal claims; and to third parties in connection with a merger, acquisition, financing, reorganization, or sale of all or part of our business (subject to appropriate confidentiality and data protection commitments).

Most of our personal data processing takes place within the European Economic Area (EEA): our hosting, databases, cache, transactional email and error monitoring run in EU regions. End Recipient shipment data is, where applicable, transmitted to Greek and other EEA-based carriers (ACS, BCS, BoxNow, Geniki Taxydromiki, Speedex, TCS, and DHL Group), which receive the data within the EEA.

Some services involve, or may involve, the transfer of personal data outside the EEA:

• Google LLC (Google Maps Platform: the Geocoding, Address Validation and Places APIs; United States), an independent controller, on its own Data Privacy Framework certification and the Standard Contractual Clauses in its controller terms (Section 5.5);
• PostHog, Inc. (product analytics and session replay, only with your consent), under Standard Contractual Clauses;
• SolarWinds (Papertrail) (service logs, United States), holding identifiers only, under Standard Contractual Clauses (Module Three) with a transfer impact assessment;
• GitHub, Inc. (source-code hosting and continuous integration, United States), under the EU–US Data Privacy Framework; production personal data is not intentionally processed in CI;
• Mistral AI SAS (reading courier invoices), whose global endpoint has no committed location, under its Data Processing Addendum (an adequacy decision, other appropriate safeguards, or Standard Contractual Clauses);
• Google Cloud EMEA Limited (Google Workspace: our email, including support and replies to delivery status emails), which Google's terms let process data in any country where Google or its sub-processors have facilities, under Google's Cloud Data Processing Addendum (a data protection framework Google adopts, otherwise Standard Contractual Clauses);
• FedEx and UPS: for rate quotes, they receive no street, name or contact details, only what's needed to price the parcel, such as the postcode, town, region and country; for bookings, through the Customer's own account, FedEx through its Greek company, and UPS through UPS of Greece, Inc., a US company with a branch in Greece. The Customer is the controller and exporter of what it discloses, and each courier may transfer data onward under its own arrangements.

In addition, some of our EEA-based sub-processors belong to groups headquartered outside the EEA (for example, Salesforce, MongoDB, Vercel, Sentry, Mailgun, Redis Ltd. and Amazon Web Services), whose staff may, in limited circumstances, access the data from outside the EEA, for example for technical support.

Where personal data is transferred outside the EEA, or such access is possible, we rely on the transfer mechanisms of Chapter V GDPR:

• the EU–US Data Privacy Framework ("DPF"), where the recipient is certified;
• the European Commission's Standard Contractual Clauses (Decision (EU) 2021/914), supplemented by appropriate technical and organisational measures; and
• adequacy decisions, where the recipient's country has one (for example, Israel and the United Kingdom, for access by Redis group staff).

The location of processing for each sub-processor, and its safeguard, is identified at /subprocessors. You may request a copy of the relevant transfer safeguards by contacting privacy@pircel.com.

We retain personal data only for as long as necessary to fulfil the purposes set out in this Privacy Policy, including to comply with legal, accounting, tax, or reporting requirements. Specific retention periods include:

• Contact-form submissions and demo-booking data: up to 24 months from the date of last contact, unless a customer relationship is established (in which case Customer retention rules apply).
• Account data of authorized users of Customers: for the duration of the Customer's agreement and, after it ends, until the Customer asks us to delete it, which we do within 30 days of the request.
• End Recipient shipment data (processed as Processor): for the periods in Schedule A of the Data Processing Agreement, as the Customer's instruction. The recipient's name, company, street address, phone, email, notes and labels are kept for 24 months, or for the period the Customer sets in its settings, from 7 months to 5 years, counted from when the shipment is finished (delivered, collected, returned or cancelled) or, for one that never finishes, from its last status update. The rest of the shipment's record is kept for 6 years, or until a tax audit or dispute concerning it ends. A rate quote without an order keeps no street, name or contact details, and is deleted 30 days after its last change. Section 17.6 sets out the periods for Pircel Shipping for Shopify.
• Store settings after a Customer disconnects a store: 30 days, because the Customer's agreement with Pircel continues (Art. 6(1)(b)).
• Audit logs and security records: 12 months, longer where required to investigate or respond to a security incident.
• Records of cookie consent: 24 months from each record.
• Error reports and Session Replay recordings: up to 90 days.
• Service logs: 7 days.
• Billing and accounting records, including our invoices to Customers: retained for the period required by Greek tax and accounting law.
• Marketing data: until you withdraw your consent or object.

Database backups hold a copy for up to 8 days after these periods. After the applicable retention period, we delete or anonymize the personal data unless we are legally required to retain it.

We implement appropriate technical and organizational measures to protect personal data against unauthorized or unlawful processing and against accidental loss, destruction, damage, or disclosure. These measures include:

• Encryption of data in transit (TLS 1.2 or higher) and at rest (AES-256);
• Strong authentication, including signed-token sessions and one-time-passcode verification;
• Access to production data only for named staff whose role needs it, through individual accounts with multi-factor authentication; today, two people have it;
• Audit logging of administrative activities;
• Regular reviews of our security posture and vendor security;
• Storage of secrets in dedicated secret-management systems rather than in source code; and
• Incident response procedures.

No method of transmission over the Internet or method of electronic storage is 100% secure, but we work continuously to improve our security posture.

Subject to applicable law, you have the following rights in respect of your personal data:

• Right of access (Art. 15) — to confirm whether we process personal data about you and to obtain a copy.
• Right to rectification (Art. 16) — to correct inaccurate or incomplete data.
• Right to erasure (Art. 17) — to request deletion of your personal data in certain circumstances.
• Right to restriction (Art. 18) — to request that we limit processing in certain circumstances.
• Right to data portability (Art. 20) — to receive your personal data in a structured, commonly used, machine-readable format and to transmit it to another controller.
• Right to object (Art. 21) — to object to processing based on legitimate interests or for direct marketing purposes.
• Right to withdraw consent — where processing is based on your consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
• Rights related to automated decision-making (Art. 22) — although, as noted in Section 5.9, we do not carry out such processing.

End Recipients: if you wish to exercise rights in respect of personal data we process about you as a Processor on behalf of a Merchant (for example, shipment data), please contact the Merchant. We will assist the Merchant in responding to your request as required under the applicable Data Processing Agreement.

To exercise any of these rights, contact us at privacy@pircel.com. We may need to verify your identity before responding. We will respond within one (1) month of receiving your request; this period may be extended by up to two further months for complex requests, in which case we will inform you of the extension and the reasons for it.

Requests are free of charge unless they are manifestly unfounded or excessive, in which case we may charge a reasonable fee or refuse to act on the request.

If you believe our processing of your personal data infringes the GDPR or other applicable law, you have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your habitual residence, place of work, or place of the alleged infringement.

The supervisory authority for Pircel is the:

Hellenic Data Protection Authority (HDPA)

Αρχή Προστασίας Δεδομένων Προσωπικού Χαρακτήρα

1–3 Kifisias Avenue, 115 23 Athens, Greece

Telephone: +30 210 6475600

Website: www.dpa.gr

Email: contact@dpa.gr

We would, however, appreciate the opportunity to address your concerns directly before you contact the authority — please contact us first at privacy@pircel.com.

The Website and the Service are not directed to children under the age of 18. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us at privacy@pircel.com and we will take steps to delete the data.

In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of natural persons, we will notify the Hellenic Data Protection Authority without undue delay and, where feasible, within 72 hours of becoming aware of the breach. Where the breach is likely to result in a high risk to your rights and freedoms, we will also notify you directly without undue delay.

We may change this Privacy Policy to reflect changes in our practices, the services we offer, or the law. The current version is posted here with its date, and every version is kept unchanged at its own dated address. Where a change is material, we tell Customers by email and show a notice on the Website before it applies.

If you're a shopper: this section explains how Pircel handles your details for shops that use Pircel Shipping. The shop you bought from decides how your details are used, and Pircel processes them on its behalf. To see, correct or delete your details, contact that shop. If you write to us at privacy@pircel.com, we pass your request to the shop and tell you that we have, and to which shop. The courier delivering your parcel handles your details for the delivery under its own privacy notice.

If you're a merchant: this section explains:

• what personal data the app and the Pircel platform process for your store;
• why we process it;
• who receives it, and where;
• how long we keep it.

It adds to our Data Processing Agreement (DPA).

Who we are

• ΠΙΡΣΕΛ Ι.Κ.Ε. ("PIRCEL P.C."), a Greek private company, 32 Voukourestiou Street, 106 71 Athens, Greece. G.E.MI. No. 165318701000.
• Privacy contact: privacy@pircel.com.

17.1 Our role

• Your customers' data: this means the people you ship to, and shoppers who see shipping rates at your checkout. For this data, you are the controller and Pircel is your processor (Article 28 GDPR). We process it only on your instructions, as set by:
  • your contract with us and the DPA;
  • your settings in the app and in Pircel.
• Your own account data: this means data about you and your staff as Pircel account holders, and our own security and accounting records. For this data, Pircel is the controller, as the rest of this Privacy Policy describes.
• Couriers receive delivery data as independent controllers, under their own privacy notices.
• Shopify is your store's platform. The app reads and writes your store's data only with the permissions you grant when you install it.

17.2 The data we process

We don't ask for special categories of personal data, such as health data. Delivery notes are used only for the delivery and shown to you in the dashboard. They're printed on the courier's label only if you turn that on. They're used for nothing else: not for analytics, support search or training any system.

17.3 Why we process it

• To quote shipping rates at your checkout.
• To check and standardise delivery addresses.
• To book the shipment with the courier that you or your shopper choose, and create the label.
• To record cash-on-delivery amounts and match them against the courier's remittance reports. The courier collects the cash and pays it to you directly; the money never passes through Pircel.
• To write tracking back to your Shopify order and keep its fulfilment status up to date.
• To send delivery status emails to your recipients, if you turn them on. These are service messages about their delivery, sent on your instruction, not marketing. They come from info@pircel.com and name your store prominently. Replies go to the reply-to address you set in your Pircel settings. If you set none, they reach Pircel at info@pircel.com; we forward each one to you and then delete it.
• To show your shipments to your users in the Pircel dashboard, with delivery statistics.
• To check courier invoices against your shipments.
• To help you when you ask for support, and to keep the service secure and working. This includes error reports and logs, which are configured to exclude personal data. We review that configuration periodically.

What we don't do:

• We don't use this data for marketing.
• We don't sell it, or share it beyond the recipients below.
• We don't use it for automated decisions with legal or similarly significant effects.

17.4 Who receives it, where, and on what safeguard

The full list of our sub-processors is on our Sub-processors page, https://www.pircel.com/subprocessors, which is dated and versioned. We email you about changes as described in the DPA.

17.5 Where it's processed

We process your customers' data mainly in the EEA: Heroku's Europe region, MongoDB Atlas in Paris, Mailgun's EU region and Sentry in Frankfurt. Some of these providers belong to US groups, and their staff may access data from the US, as the table shows. Emails to info@pircel.com, including replies to delivery status emails, are received in Google Workspace; under Google's terms, Google may process them in any country where it or its sub-processors have facilities.

Outside the EEA:

• FedEx and UPS:
  • A rate quote sends them no street, name or contact details: only what's needed to price the parcel, such as the postcode, town, region and country.
  • A booking goes through your own account with them, so the disclosure is yours, as controller, made through Pircel on your instruction. FedEx books through its company in Greece. UPS books through UPS of Greece, Inc., a US company with a branch in Greece.
  • Each courier may transfer the data onward outside the EEA under its own arrangements, which you can ask it about.
• Google (United States), as an independent controller, on its own Data Privacy Framework certification and the Standard Contractual Clauses in its controller terms.
• Papertrail (United States), on the Standard Contractual Clauses, with a transfer impact assessment.
• The other sub-processors in the table and on our Sub-processors page, each on the safeguard shown there.

17.6 How long we keep it

In the app:

• The app keeps a recipient's details until 90 days after the shipment is delivered, returned or cancelled, and never longer than 1 year after booking.
• When you uninstall the app, Shopify asks us 48 hours later to delete your store's data, and the app deletes it then.
• Error reports don't name your store. They refer to it by a reference the app deletes along with your store's data.

In Pircel:

• Rate quotes with no order: a quote holds the postcode, town, region and country, the cart's weight, the courier and the quoted price, and is deleted 30 days after it was last changed. Anything more a store sends with a quote, such as a street address, name or contact details, is discarded when it arrives. Database backups hold a copy for up to 8 more days.
• Booked shipments: as your instruction to us, counted from when the shipment is finished (delivered, collected, returned or cancelled) or, for one that never finishes, from its last status update:
  • the recipient's name, company, street address, phone, email, delivery notes and label are deleted after 24 months, or after the period you set in your Pircel settings, from 7 months to 5 years. A period over 24 months is your decision as controller and needs a purpose of your own. The dashboard reminds you of this when you choose one;
  • the map coordinates that Google's address check returns, and its standardised street line, are kept with the recipient's other details, for that shipment only, and deleted with them. The standardised postcode, town, county and country stay with the shipment's record, and Google's place ID for the address may be kept.
• The rest of the shipment's record stays for 6 years, counted from the same point: the order number, the tracking codes, the town, postcode and country, the amounts (including cash on delivery), the items, the parcels, the courier and the service. With your order records or the courier's, the order number and tracking codes still lead back to your customer, so we keep treating that record as personal data. After 6 years the record is deleted, unless a tax audit or a dispute that concerns it is still open; then it's kept until that ends.
• What stays after that: our charge records for each shipment (its id, the amounts, the dates, the postcode or town and country, the weights, the courier and the service; no names or contact details), kept as our financial records for at least the tax period: 5 years, under Law 5104/2024. Also daily delivery statistics for your store, by courier and region, which hold no shipment details.
• Courier invoices: each invoice line (its tracking code, dates, the courier's destination area, service, weight and price) is kept for the tax period. The full text read from a PDF invoice, which can name recipients, is deleted after the period that applies to recipients' names and addresses, counted from the invoice date.
• Documents you upload to a shipment, such as customs invoices:
  • for a parcel that stays in the EU, they're deleted with the recipient's name and address;
  • for a parcel leaving the EU's customs territory, they're kept until 3 years after the end of the year it was shipped, as your instruction to us. That's the period EU customs law sets for keeping customs documents. Then they're deleted.
• Your store's settings after you disconnect it: Pircel keeps them for 30 days, so they come back if you reconnect, then deletes them. They hold nothing from Shopify except your store's domain.

When your contract ends: the periods above keep applying, and your customers' data is deleted as they run out. If you ask us at privacy@pircel.com, we return your customers' data to you, or delete it sooner, within 30 days of your request. Only our own charge records, which hold no names or contact details, are kept.

Error reports and logs: error reports up to 90 days; service logs 7 days.

Backups: daily database snapshots, of which the last 8 are kept.

17.7 Security

• Data is encrypted in transit and at rest. Your Pircel connection key is also sealed with an app-level key.
• Staff accounts use multi-factor authentication and a password manager.
• Access to production data is given on a least-privilege basis, only to named staff whose role needs it. Today two people have it.
• Test systems use test data only.

The full measures are in the DPA.

17.8 Requests and your customers' rights

• Your customers should contact you, as the controller. We help you answer them, as the DPA sets out. If a shopper writes to us instead, we pass the request to you and tell the shopper that we have, and to whom.
• Requests through Shopify:
  • When you receive a customer's data request through Shopify, the app passes it to Pircel. Within 30 days, Pircel sends you the shipment records it holds for that customer's orders. Rate quotes hold no name or contact details, so there are none to search by email or phone.
  • When you receive an erasure request through Shopify, the app deletes its copy at once. Within 30 days, Pircel removes the customer's name, contact details, street address and notes from their shipments. The order number, tracking codes and the town or postcode stay for as long as section 17.6 says. If you, as controller, need a record kept for a legal obligation or a legal claim, tell us, and we keep only what you instruct for as long as you need it.
• Contact: privacy@pircel.com, or Pircel, 32 Voukourestiou Street, 106 71 Athens, Greece.
• Complaints: anyone may complain to the Hellenic Data Protection Authority (www.dpa.gr).

For any questions, concerns, or requests regarding this Privacy Policy or our processing of personal data:

ΠΙΡΣΕΛ Ι.Κ.Ε. ("PIRCEL P.C.")

32 Voukourestiou Street, 106 71 Athens, Greece

Privacy contact: privacy@pircel.com

General contact: contact@pircel.com