Legal
Privacy policy
Storra helps Shopify merchants add sections to their themes. To do that we store as little as possible: your shop's domain, the access Shopify grants the app, and your plan, credits and purchases. We never access your customers or orders.
1. Who is responsible
The controller for the processing described here, within the meaning of the EU General Data Protection Regulation (GDPR), is:
NICCOS[Street and number][Postcode City]Germanyprivacy@niccos.comTODO(legal) Add the full legal entity name, registered address, commercial register entry and managing director(s). Check whether NICCOS must appoint a data protection officer (Art. 37 GDPR, § 38 BDSG) and name them here if so.
2. Scope of this policy
This policy covers the Storra app for Shopify (“the app”) and these public pages. It applies to merchants who install the app and to their staff who use it inside the Shopify admin. Shopify itself processes data under its own privacy policy.
3. Data we process
The app requests two Shopify permissions only: reading and writing themes. Within that, we process:
sp- prefix).To show your themes and install the sections you choose. To let you try a section first, the app can copy your live theme into an unpublished theme named “Storra Preview” in your store. Theme content is read from Shopify when needed and not copied into our database.Contract (Art. 6(1)(b) GDPR)When you open the app inside the Shopify admin, Shopify passes a signed session token that identifies your shop and your staff account. We verify it to authenticate the request; we don't store names, email addresses or other profile data of you or your staff.
Payments are processed by Shopify and appear on your Shopify invoice. We never see card or bank details.
The app and these pages don't use analytics, advertising or tracking cookies. The app runs inside the Shopify admin and relies on Shopify's own technically necessary mechanisms there.
TODO(legal) Confirm the legal bases above. If onboarding answers are ever used by NICCOS for sales or lead generation (not just recommendations), this needs its own purpose, legal basis and probably consent. Check whether the billing records (charges, credit log) are subject to retention duties under German commercial and tax law (§ 257 HGB, § 147 AO) given that Shopify invoices the merchant, and adjust the retention section if so.
4. No customer data
Storra has no access to your customers, orders or any other buyer data and stores none. Shopify still requires every app to accept privacy requests about customers (“customer data request” and “customer redact”). We confirm these requests and record that we hold no data for the customer.
5. Sections in your storefront
Sections you install become regular files in your theme and run on your storefront like the rest of your theme. They load no third-party scripts, set no tracking and send no data to us. Some sections remember display state in the visitor's browser for the current session (for example, a countdown bar keeps its timer in session storage). That data stays in the browser and is never sent to us.
For your storefront you are the controller towards your visitors, and your own privacy notice applies.
TODO(legal) Confirm whether session storage used for display state is “strictly necessary” under § 25(2) TDDDG / Art. 5(3) ePrivacy Directive, or whether merchants need to cover it in their consent banner.
6. Service providers and recipients
- Shopify runs the platform the app is part of, handles billing and sends the data listed above to the app through its APIs.
- Hosting provider runs our servers and database in the European Union and processes data on our behalf under a data processing agreement (Art. 28 GDPR). TODO(legal) Name the hosting and database provider and region once production hosting is chosen.
- Shopify CDN: our pages load a font stylesheet from cdn.shopify.com, which means your browser sends your IP address to Shopify.
We don't sell data and don't share it with advertisers.
TODO(legal) Describe transfers to third countries (Shopify entities in Canada/the US, possibly the hosting provider) and the safeguards relied on (adequacy decision / EU-US Data Privacy Framework / standard contractual clauses).
7. Retention and deletion
- When you uninstall the app, we delete your shop's access data (sessions) immediately. The app data holding your onboarding answers is cleaned up by Shopify, which decides how long it keeps it after an uninstall. We keep your plan, credits and unlocked sections for now, so they are restored if you reinstall.
- 48 hours after uninstalling, Shopify asks us to erase your shop's data. We then delete everything we hold for your shop: account, credit log, charges, unlocked sections and NICCOS client status.
- Technical logs are kept for a limited period and then deleted automatically. TODO(legal) Set the log retention period (typically 7–30 days) to match the hosting setup.
- Section files in your theme belong to you and stay in your theme after uninstalling. You can delete them in the Shopify theme code editor (files starting with
sp-). The same goes for the “Storra Preview” theme, which you can delete under Online Store › Themes.
8. Your rights
Under the GDPR you have the right to:
- access your data (Art. 15)
- rectification (Art. 16)
- erasure (Art. 17)
- restriction of processing (Art. 18)
- data portability (Art. 20)
- object to processing based on legitimate interest (Art. 21)
To exercise them, write to privacy@niccos.com and include your shop's myshopify.com domain. You can also lodge a complaint with a data protection supervisory authority, in particular in the EU member state where you live or work. TODO(legal) Name the supervisory authority competent for NICCOS (depends on the federal state of the registered office).
9. Security
All traffic to the app is encrypted with TLS and requests from Shopify are verified by signature. In your themes the app only writes its own section files (prefixed sp-). The one exception is the “Storra Preview” theme it creates for trying sections, where it also places the section in a page template. It never publishes a theme.
10. Changes to this policy
We update this policy when the app changes how it handles data. The date at the top shows the current version. Questions? Contact support or write to privacy@niccos.com.