Privacy Policy

This Privacy Policy explains how personal data is processed when you use the Clawzia website and dashboard at clawzia.com.

It has two parts:

• Part A covers the processing for which we are responsible as controller: our website, the dashboard, merchant accounts, billing, support, the installation service, shop handovers, the free compliance checker and the protection of our platform against abuse.
• Part B covers withdrawal statements and cancellation declarations that consumers send to online shops through Clawzia. For these, the shop is the controller and we process the data only on the shop's behalf, as its processor.

In short

• We collect only the data we need to provide the service.
• Clawzia is operated by a company established in the United States, and our servers are located in Buffalo, New York, United States (sections A4 and B6).
• The withdrawal widget on shop websites sets no cookies, uses no browser storage and loads no third-party resources.
• Our own website uses only strictly necessary cookies (listed in section A7). We do not use advertising or tracking cookies.
• Our website analytics work without cookies and store no IP addresses.
• In our database and our rate-limiting store, IP addresses are stored only as a keyed hash. Our web server's logs contain full IP addresses and are deleted at most 15 days after they are written.
• We do not sell personal data and we do not send unsolicited marketing messages.

Part A: Processing for which we are the controller

A1. Who is responsible

The controller is KELHOS BRAND LLC, a limited liability company under the laws of the State of New Mexico, USA, 8206 Louisiana Blvd NE, Ste A #7751, Albuquerque, NM 87113, USA, email contact@clawzia.com ("we", "us").

Data protection contact: we have not appointed a data protection officer. Write to contact@clawzia.com for all privacy questions and requests.

Representative in the European Union (Art. 27 GDPR): we are not established in the European Union. As at 29 September 2026 we have not appointed a representative in the Union. Until we do, please write to us directly at contact@clawzia.com. If we appoint a representative, we will publish its name and address here, in the imprint and in the Data Processing Agreement.

A2. What data we process, why, on which legal basis and for how long

Visiting our website

• Data: IP address, date and time of the request, requested page, referring page, browser and operating system (user agent). This data is processed by our web server when you open a page.
• Purpose: to deliver the website, to keep it secure and to detect and prevent abuse.
• Legal basis: our legitimate interest in a secure and working website (Art. 6(1)(f) GDPR).
• Retention: web server logs (access and error logs), which contain the full IP address, are deleted at most 15 days after they are written (daily rotation, 14 rotated files kept). Our web server also keeps full IP addresses briefly in memory for its own short-term rate limits. Where we store data for rate limiting and abuse protection in our database or rate-limiting store, we use a keyed hash of the IP address instead of the address itself. The hash cannot be turned back into the IP address without our secret key.

Website analytics without cookies

• Data: aggregated page-view counters (the day, the page, the market and the host name of the referring website), collected with a counter built into Clawzia itself. We use no third-party analytics service. The counter sets no cookies and stores no IP address (not even in hashed form), no user agent, no full address of the page and no identifier. It does not track you across websites and counts nothing if your browser sends a Do Not Track or Global Privacy Control signal.
• Purpose: to understand which pages are useful and to improve the website.
• Legal basis: our legitimate interest in improving our website (Art. 6(1)(f) GDPR).
• Retention: only aggregated counters are kept. They cannot be linked to a person.

Merchant account and sign-in

• Data: email address, name (optional), preferred language, time of the last sign-in, sign-in links and session data. We store only a hash of sign-in links and session tokens, never the tokens themselves. For sessions we also store the browser's user agent, and for sign-in requests a keyed hash of the IP address. If you arrive through a partner link, we also store the partner code with your sign-in link and, until your shop is created, with your account. We use the code to credit the partner only within 30 days of your sign-in; we remove an older code from your account at your next sign-in, when your shop is created or, at the latest, in our monthly clean-up.
• Purpose: to create and manage your account and to let you sign in securely.
• Legal basis: performance of the contract with you (Art. 6(1)(b) GDPR); for security measures, our legitimate interest in protecting accounts (Art. 6(1)(f) GDPR).
• Is it required? You are not obliged by law to give us this data. Your email address is needed to create an account and to sign in; without it we cannot provide the service to you. Your name is optional.
• Retention: sign-in links expire after 15 minutes. Unused links are deleted after they expire, used links one day after use. Sessions end when you sign out, and at the latest 30 days after you signed in (12 hours for our own staff accounts); ended sessions are deleted. Account data is kept while the account exists and for up to 60 days after it is closed (30 days to export your data, then deletion within 30 days).

Shop settings

• Data: shop name, legal entity name, country, website address and domains, notification and support email addresses, languages, time zone and widget settings.
• Purpose: to provide the service to you. The legal entity name and the support email address are shown to your consumers in the withdrawal form and in emails.
• Legal basis: performance of the contract (Art. 6(1)(b) GDPR).
• Retention: while the account exists, then as described in the Terms of Service.

Platform apps

• Data: if you install Clawzia through an app of a shop platform, we receive the store's identifier from the platform. For Shopify we do not store any data about your store: the access token used during the installation is discarded. For BigCommerce we store the store identifier, the permissions granted, an encrypted access token and the installation dates; the token is erased when you uninstall the app.
• Purpose: to add the widget to your shop.
• Legal basis: performance of the contract (Art. 6(1)(b) GDPR).
• Retention: for BigCommerce, the installation record (store identifier, permissions and dates, without the token) is kept after you uninstall the app, so that a later re-installation is handled correctly. It contains no data of your consumers.

Subscription and billing

• Data: plan, billing period, subscription status, trial and grace period dates, the customer and subscription identifiers of our payment provider, and payment events (amount, currency and status). At checkout you also enter your billing name, billing address, email address and, if you have one, your VAT identification number. These details, your invoices and your payment method are kept in our account with our payment provider. We never receive your full card or bank details.
• Purpose: to sell and manage your subscription, to calculate taxes, to issue invoices and to meet our accounting and tax obligations.
• Legal basis: performance of the contract (Art. 6(1)(b) GDPR) and compliance with legal obligations, in particular accounting and tax law (Art. 6(1)(c) GDPR).
• Payment provider: we sell the subscriptions ourselves. Stripe, LLC ("Stripe") processes the payments, calculates taxes and creates the invoices on our behalf. For its own purposes, such as fraud prevention and its legal obligations as a payment service provider, Stripe processes data under its own responsibility and privacy policy. On Stripe's pages (checkout and customer portal) Stripe sets its own cookies under its own policy.
• Retention: invoices and accounting records for as long as applicable accounting and tax law requires; the other billing data while your account exists.

Service emails

• Data: your email address, the content of the email and its delivery status. For each email we keep a delivery record with the recipient address, the subject line and the delivery status. (Records of emails about withdrawal statements and cancellation declarations are described in Part B.)
• Purpose: to send sign-in links, notifications about withdrawal requests, billing and grace-period notices, and important information about the service or these documents.
• Legal basis: performance of the contract (Art. 6(1)(b) GDPR).
• Retention: delivery records of sign-in link emails are deleted after 7 days. Other delivery records that do not concern a withdrawal statement or cancellation declaration (for example billing, partner, installation-service, shop handover or checker emails) are deleted after 90 days. Records of emails about a withdrawal statement or cancellation declaration are deleted together with it (Part B). Delivery records of a shop are also deleted when the shop is deleted.

We do not send newsletters or marketing emails. If we introduce them, we will send them only if you have agreed to receive them, and you will be able to unsubscribe at any time.

Support and contact

• Data: your contact details and the content of your message.
• Purpose: to answer your request.
• Legal basis: performance of the contract or steps before entering into it (Art. 6(1)(b) GDPR); otherwise our legitimate interest in answering enquiries (Art. 6(1)(f) GDPR).
• Channels: email (our mailbox is hosted by Zoho, see our list of sub-processors) and, if our website shows a WhatsApp chat link, WhatsApp. We only reply to messages you send us; we do not contact people through WhatsApp on our own initiative. If you use WhatsApp, the provider of WhatsApp also processes your data under its own privacy policy. You can always contact us by email instead.
• Retention: 24 months after the last message of the conversation, then we delete it.

Installation service

• Data: your contact name and email address, the website address and shop platform, your notes (including your preferred time window), the status and payment status of the order, and internal notes of our team about the installation.
• Access to your shop: we never ask for or accept passwords. You give our team access through your shop platform's own staff or collaborator invitation, sent to contact@clawzia.com, and you can remove that access when the installation is finished.
• Purpose: to carry out the installation you ordered.
• Legal basis: performance of the contract (Art. 6(1)(b) GDPR); for payment records, compliance with legal obligations (Art. 6(1)(c) GDPR).
• Retention: the order is kept with your account (see "Merchant account and sign-in"); payment records for as long as accounting and tax law requires. Payments for the installation service are handled like subscription payments.

While we work in your shop's administration area, we may see personal data of your customers, for example orders or customer accounts. We do not copy, export or otherwise use this data. This access is processing on your behalf and is covered by our Data Processing Agreement (external link).

Shop handover (Agency plan)

• Data: the email address of the person an agency invites to take over a shop, the time of the invitation, its status and expiry and, once it is accepted, which account accepted it and when.
• Source: if you were invited, we received your email address from the agency that sent the invitation.
• Purpose: to send the invitation and to move the shop to the invited person's own account.
• Legal basis: performance of the contract with the agency and steps taken at the invited person's request before entering into a contract (Art. 6(1)(b) GDPR); otherwise our legitimate interest in carrying out the handover the agency asked for (Art. 6(1)(f) GDPR).
• Retention: invitations that are not accepted are deleted 30 days after their link expires. Accepted handovers are kept as the ownership history of the shop until the shop or the agency's account is deleted.

Free compliance checker

• Data: the website address you enter, the result of the check, the time of the check and a keyed hash of your IP address. If you ask for the result by email, also your email address.
• Purpose: to run the check, to show you the result and to prevent abuse of the checker.
• Legal basis: our legitimate interest in offering the checker and protecting it against abuse (Art. 6(1)(f) GDPR). We send a result by email only with your consent, which you confirm through a link in a first email (Art. 6(1)(a) GDPR). You can withdraw your consent at any time.
• Retention: the result of a check is shown and reused for 24 hours, so that repeated checks of the same website within that time do not load it again. The record of the check (website address, result, time and the keyed hash of your IP address) is kept for 30 days to protect the checker against abuse and is then deleted. If you ask for the result by email, your email address is stored in encrypted form and deleted when the report has been sent. If you do not confirm the request, it is deleted shortly after the confirmation link expires (the link is valid for 24 hours); if the report cannot be delivered, your address is deleted 24 hours after the link expired. The remaining request record (a keyed hash of your email address, used to limit how many reports one address receives, and timestamps) is deleted together with the check record after 30 days.

Partner program

• Data: partner identity and contact details, partner code, which merchants signed up through the partner code, commission records and the details a partner sends us so that we can pay the commission.
• Purpose: to run the partner program and pay commissions.
• Legal basis: performance of the contract with the partner (Art. 6(1)(b) GDPR) and legal obligations for accounting (Art. 6(1)(c) GDPR).
• Retention: while the partnership exists and afterwards for as long as accounting and tax law requires.

Audit and security log

• Data: which account performed which action in the dashboard and when, with a keyed hash of the IP address. When you accept our Terms of Service and Data Processing Agreement, the log records the version and the time of your acceptance.
• Purpose: security, investigating incidents and proving what was changed and by whom, and what a merchant accepted.
• Legal basis: our legitimate interest in the security and traceability of the service (Art. 6(1)(f) GDPR), which is also in the interest of our customers.
• Retention: entries about a withdrawal statement are deleted together with it (entries about actions on it by the shop's users, by Clawzia staff or by the system within 45 days afterwards); the entries that record your acceptance of our Terms and Data Processing Agreement are kept while your account exists and are deleted when the account is deleted (see "Merchant account and sign-in"); all other entries are deleted 36 months after they were created.

The audit log also records when a consumer confirms a withdrawal statement or cancellation declaration. Those entries are described in Part B.

Platform security and abuse protection

• Data: when a browser or a plugin contacts our servers, for example to open a shop page with the widget, to load the widget's settings, to open the hosted form or to send a statement: the IP address, browser information, the time and the path of the request (without any query string) in our web server logs; a keyed hash of the network of the IP address (the IPv4 address, or the IPv6 /64 prefix) and, for some limits, of an email address in our rate-limiting counters; and application log lines about rejected cancellation attempts (time, shop, channel, error code, names of the fields concerned and the keyed hash of the IP network, but no name, email address or typed text). Requests for the widget script itself are not written to the web server log.
• Purpose: to keep the service secure and available, to detect and prevent abuse such as automated or mass submissions, and to protect the withdrawal function of every shop.
• Legal basis: our legitimate interest in the security and availability of our service (Art. 6(1)(f) GDPR). We keep the data to a minimum and use it for nothing else.
• Retention: web server logs at most 15 days after they are written; rate-limiting counters at most 24 hours; application log lines at most 60 days.
• Role: for this technical request data we are the controller. It is separate from the content of statements, for which we are the shop's processor (Part B).

A3. Recipients

We share personal data only where needed for the purposes above:

• service providers that process data on our behalf, such as hosting, email delivery and our support mailbox (see our list of sub-processors (external link));
• Stripe, our payment provider, for payments, taxes and invoices (see "Subscription and billing");
• professional advisers bound by confidentiality, such as lawyers and accountants, where needed;
• authorities and courts, where we are legally required to do so;
• a buyer or successor of our business, if the business is transferred, subject to this Privacy Policy.

A4. Transfers outside the EU/EEA

We are established in the United States, and our servers are located in Buffalo, New York, United States. When you use our website or dashboard, your data is therefore processed outside the EU/EEA. Where we or our service providers transfer personal data to a country outside the EU/EEA that does not have an adequacy decision of the European Commission, we use the standard contractual clauses adopted by the European Commission (Art. 46(2)(c) GDPR) or another safeguard permitted by the GDPR, and additional measures where needed. The safeguard for each provider is stated in the list of sub-processors. You can ask us for a copy of the relevant safeguards.

A5. Your rights

You have the right:

• to access your personal data (Art. 15 GDPR);
• to have incorrect data corrected (Art. 16 GDPR);
• to have your data deleted (Art. 17 GDPR);
• to restrict processing (Art. 18 GDPR);
• to receive your data in a portable format (Art. 20 GDPR);
• to object to processing based on our legitimate interests (Art. 21 GDPR);
• to withdraw your consent at any time, with effect for the future (Art. 7(3) GDPR).

To exercise your rights, write to contact@clawzia.com. We may ask you to confirm your identity. We answer within the time limits set by Art. 12 GDPR.

A6. Right to complain

You can lodge a complaint with a data protection supervisory authority, in particular in the EU country where you live, work or where the alleged infringement took place.

A7. Cookies and similar technologies

Our website and dashboard use only cookies that are strictly necessary to provide the service you request. We do not use advertising, profiling or tracking cookies, and our analytics do not use cookies. We choose the language of pages from your browser's language setting without setting a cookie.

The withdrawal widget that shops embed on their websites sets no cookies, uses no local storage, session storage or other browser storage, and does not load resources from third parties. The hosted withdrawal form sets no cookies either.

A8. Security

We protect personal data with technical and organisational measures, including encrypted connections (HTTPS), encrypted backups, access control, storing only hashes of sign-in and session tokens, keyed hashes instead of IP addresses in our database and rate-limiting store, short retention of server logs, and logging of administrative actions. The measures are described in Annex 2 of our Data Processing Agreement.

A9. Automated decisions

We do not make decisions based solely on automated processing that produce legal effects concerning you or similarly significantly affect you (Art. 22 GDPR). Our abuse protection may automatically block requests for a short time, for example when too many requests arrive from the same source. You can try again later or contact us.

A10. Children

Our service is intended for businesses and is not directed at children.

Part B: Withdrawal statements and cancellation declarations (we process data on behalf of shops)

B1. Our role

Online shops ("merchants") use Clawzia to offer their consumers an online withdrawal function and, where a shop has switched it on, a button to cancel subscriptions and other continuing contracts. When you, as a consumer, send a withdrawal statement or a cancellation declaration (both called "statement" in this part) to a shop through its Clawzia widget or form, the shop is the controller of your data. We process the data only on behalf of the shop and according to its instructions, as its processor (Art. 28 GDPR). This processing is governed by our Data Processing Agreement (external link) with the shop.

For questions about your withdrawal, your cancellation or your order, and to exercise your data protection rights regarding your statement, please contact the shop. Its name is shown in the form and in the confirmation email. If you contact us, we will forward your request to the shop.

B2. Which data is processed

Only the data needed to record and confirm the statement:

• name;
• email address (to send you the confirmation);
• order number or contract reference;
• for a withdrawal: the items concerned and a message, if you enter them (both optional);
• for a cancellation: the type of termination (ordinary or extraordinary), the reason for an extraordinary termination, and the requested end of the contract (at the earliest possible time, or a date you choose);
• the language you used;
• the date and time you started and confirmed the statement, and the shop's time zone;
• the receipt ID and a cryptographic hash of the statement;
• the labels shown to you in the form (as evidence for the shop);
• a keyed hash of the network of your IP address, for abuse protection and as evidence (statements recorded before we stopped collecting it also contain the user agent of your browser);
• for a cancellation: a note for the shop if the form was sent unusually fast, which can indicate an automated submission (the cancellation is still recorded);
• an audit log entry that records the confirmation (time, receipt ID and the keyed hash of your IP address);
• a record of each email sent about the statement: recipient address, subject line and delivery status. The subject contains the order reference and, in the shop's notification, your name.

If a cancellation cannot be recorded (for example because a required field is missing or a limit was reached), our application log records the attempt without your name, email address or anything you typed. This log is described in Part A, "Platform security and abuse protection".

You are never asked for a reason for your withdrawal. For a cancellation, a reason is asked for, and required, only if you choose an extraordinary termination. You do not need an account. Your name, email address and order or contract reference are needed to record and confirm your statement; without them the form cannot be sent. If you do not want to use the form, you can contact the shop directly.

B3. Purposes

• to record your statement and show you the confirmation screen;
• to send you an acknowledgement email with the content of your statement and the date, time and time zone of its submission; for a cancellation also the requested end of the contract and the button wording used, and you can download a copy of your declaration as a text file;
• to notify the shop and show the statement in the shop's dashboard;
• to issue a receipt that can be verified on our website. The verification page shows only the shop name, the time of confirmation, the hash and the status; it never shows your personal data;
• to protect the withdrawal and cancellation functions against abuse.

If unusually many acknowledgement emails are requested within 24 hours for the same email address, or from the same network, we hold the acknowledgement email to prevent the form from being misused to send emails to other people. Your statement is still recorded and receipted, and the shop can see it in its dashboard. A member of the Clawzia team reviews held emails and releases them; the team sees only the domain of the recipient address, never the subject or the content.

B4. Retention

• Statements that are started but never confirmed expire after 24 hours and are deleted 7 days later.
• Confirmed withdrawal statements and cancellation declarations are kept for 3 years by default and then deleted, unless the shop sets a different period (12, 24, 36, 60 or 120 months). The shop decides the period that fits its legal obligations.
• Email records and the audit log entry of the confirmation are deleted together with the statement.
• Application log lines about cancellation attempts that could not be recorded are kept for at most 60 days.
• Stored replies for repeated requests (encrypted copies of the answer our server gave to your browser, used so that sending the same form twice does not create two statements) are deleted after 24 hours.
• Encrypted backups are overwritten on a rolling schedule, so deleted data also disappears from backups after a limited time (at the latest 56 days).

B5. Cookies and technical data

The withdrawal widget sets no cookies, uses no browser storage and loads nothing from third parties.

When a shop page with the widget opens, your browser loads the widget and its settings from Clawzia's servers. As with any request on the internet, this transmits your IP address and information about your browser. We use this data only to deliver the widget and to protect it and the other shops against abuse. For this technical request data we are the controller, and Part A, "Platform security and abuse protection", explains what is kept and for how long: the web server logs are deleted at most 15 days after they are written, and rate-limiting counters use a keyed hash of the IP address. What you type into the form is sent to Clawzia only when you submit it.

B6. Where the data is processed

Clawzia is operated by KELHOS BRAND LLC, a company established in the United States, and the data is stored on servers in Buffalo, New York, United States. Your data is therefore transferred from the shop to us outside the EU/EEA. This transfer is based on the standard contractual clauses of the European Commission (Art. 46(2)(c) GDPR), which are part of the Data Processing Agreement between the shop and us (section 13). You can ask the shop for a copy.

Changes to this Privacy Policy

We update this Privacy Policy when our processing changes. The version number and the date of the last update are shown at the top of this page.

Contact

KELHOS BRAND LLC, 8206 Louisiana Blvd NE, Ste A #7751, Albuquerque, NM 87113, USA
Email: contact@clawzia.com

Clawzia is a technical tool and does not provide legal advice.