Privacy Policy

This Privacy Policy is published by KEET TECHNOLOGY SOLUTIONS LTD, trading as “ShopPro” and “ShopPro Commerce” (company number SC662207, registered in Scotland), whose registered office is at Suite 211, The North Quarter, 496 Ferry Road, Edinburgh, Scotland, EH5 2DL.

For the purposes of UK data protection law, we are the data controller in respect of the personal data of merchant contacts and business account holders described in this policy.

To contact us on data protection matters, email: admin@shoppro.tech

This policy covers two distinct roles:

• Controller of merchant data:ShopPro is the data controller for personal data belonging to individuals who act as contacts or account holders for merchant businesses using ShopPro Commerce. This includes names, business email addresses, phone numbers, and billing details provided during onboarding and in the course of the merchant's use of the platform.
• Processor of End Customer data:Where merchants use ShopPro Commerce to operate their own storefronts, personal data of End Customers (the merchant's own customers — members of the public placing orders) is processed by ShopPro on behalf of the merchant. In this context, the merchant is the data controller and ShopPro is a data processor acting on the merchant's documented instructions. ShopPro does not use End Customer data for its own purposes.

This policy principally addresses ShopPro's activities as data controller in relation to merchant contacts. If you are an End Customer of a merchant storefront, your primary data rights should be exercised with the merchant, who is the data controller for your data.

When a business signs up to use ShopPro Commerce, we collect the following categories of personal data from the merchant's designated contacts:

• Full name and job title / role
• Business email address
• Phone number
• Billing details (name, address, payment reference — card payment data is processed by our PSP, Viva, not by us directly)
• Communication and correspondence records (emails and messages exchanged with ShopPro)
• Platform usage data (login activity, dashboard interactions)

We process merchant contact data for the following purposes:

• Contract performance (Article 6(1)(b) UK GDPR): To set up and administer the merchant's ShopPro Commerce account, provide the platform, deliver support, and manage the commercial relationship.
• Legitimate interests (Article 6(1)(f) UK GDPR): To maintain platform security, prevent fraud and abuse, improve our product, and contact merchants about material service changes. We have assessed that our legitimate interests are not overridden by merchant contacts' interests or rights in these contexts.
• Legal obligation (Article 6(1)(c) UK GDPR): To comply with our obligations under UK law, including financial record-keeping and responding to lawful requests from regulatory authorities.

We may share personal data with the following categories of third party:

• Viva.com / Viva Wallet (PSP): Payment processing for End Customer transactions is handled by Viva. Viva acts as an independent data controller for payment card data and as a sub-processor for transaction data. Viva operates under its own privacy policy and PCI DSS obligations.
• Infrastructure and hosting providers: We use cloud infrastructure to host the ShopPro Commerce platform. These providers process data on our behalf under data processing agreements.
• Professional advisers: Legal, accounting, and audit advisers may have access to relevant data where necessary and under appropriate confidentiality obligations.

We do not sell personal data to third parties. We do not use merchant contact data for advertising or marketing purposes beyond direct communications about ShopPro products and services that are directly relevant to the merchant's use of the platform.

Where ShopPro processes personal data of End Customers (the customers of merchant storefronts), we do so solely as a data processor on behalf of the relevant merchant. This includes order details, delivery addresses, and contact information submitted by End Customers when placing orders.

In this capacity, ShopPro:

• Processes End Customer data only on the documented instructions of the merchant (i.e. to operate the platform and fulfil orders).
• Does not use End Customer data for its own commercial purposes.
• Takes appropriate technical and organisational measures to protect End Customer data.
• Will enter into a data processing agreement with merchants on reasonable request.

If you are an End Customer of a merchant storefront and wish to exercise data rights (access, erasure, correction, etc.), you should contact the merchant directly. ShopPro will cooperate with merchants in responding to such requests.

We retain merchant account data for the duration of the merchant relationship and for a period of up to six years thereafter, in accordance with our legal and contractual obligations (principally HMRC record-keeping requirements).

Following termination of a merchant's account, we will make the merchant's data available for export for a reasonable period (typically 30 days) before it is deleted or anonymised from live systems. Archived backups are retained for a shorter period and are then destroyed.

Correspondence records are retained for up to six years from the date of the communication. Platform usage logs are retained for a shorter period consistent with security and operational needs.

We aim to store and process personal data within the UK and the European Economic Area. Where data is processed outside the UK, we ensure that appropriate safeguards are in place (such as the UK International Data Transfer Agreement or equivalent adequacy arrangements) before such transfers occur.

As a data subject, you have the following rights in relation to your personal data processed by ShopPro as controller:

• Right of access: You may request a copy of the personal data we hold about you.
• Right to rectification: You may ask us to correct inaccurate data or complete incomplete data.
• Right to erasure: You may ask us to delete your personal data where we no longer have a lawful basis to retain it, subject to our legal obligations.
• Right to restriction: You may ask us to restrict processing of your data in certain circumstances (e.g. while a rectification request is considered).
• Right to data portability: Where processing is based on consent or contract and is carried out by automated means, you may request your data in a structured, commonly used, machine-readable format.
• Right to object: You may object to processing carried out on the basis of legitimate interests. We will stop processing unless we can demonstrate compelling legitimate grounds.
• Rights related to automated decision-making: We do not carry out solely automated decision-making with legal or similarly significant effects.

To exercise any of these rights, email us at admin@shoppro.tech. We will respond within one calendar month of receipt of your request.

If you believe we have not handled your personal data in accordance with UK data protection law, you have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK supervisory authority for data protection:

We would, however, appreciate the opportunity to address any concern directly before you contact the ICO. Please email us first at admin@shoppro.tech.

We take appropriate technical and organisational measures to protect personal data against unauthorised access, loss, destruction, or alteration. These include access controls, encryption in transit, and regular review of security practices.

No method of internet transmission or electronic storage is entirely secure. Where we become aware of a personal data breach that is likely to result in a risk to individuals, we will notify the ICO within 72 hours in accordance with Article 33 UK GDPR, and affected data subjects where required.

This marketing website (commerce.shoppro.tech) is a static informational site. We do not currently operate any tracking cookies, analytics pixels, or behavioural advertising on this site. If this changes, this policy will be updated and a cookie notice added.

We may update this Privacy Policy from time to time. We will indicate the updated date at the top of this page. Material changes affecting merchant contacts will be communicated by email. Continued use of ShopPro Commerce after the effective date of any change constitutes acceptance of the updated policy.