InvoNorm Privacy Policy
Controller/Processor: Fengjing (Shenzhen) Trading Co., Ltd., Rm 902, Block B, Haijing Court, Haojing Garden, No. 2 Shazui Rd, Futian District, Shenzhen, China · [email protected]
For merchant account data (your company details, login, billing) we act as controller. For personal data contained in your orders (your customers' names, addresses, order details) we act as processor on your behalf under our Data Processing Agreement.
1. What we process and why
| Data | Purpose | Legal basis |
|---|---|---|
| Merchant company data (name, address, VAT ID, IBAN, contact) | Appears on invoices; account management; billing | Contract performance (Art. 6(1)(b) GDPR) |
| Order data incl. customer name, billing/shipping address, email, line items, taxes | Generating legally required invoices; archiving; delivery | Contract performance; legal obligation of the merchant (Art. 6(1)(c)) |
| Technical logs (IP, timestamps, app events) | Security, abuse prevention, debugging | Legitimate interest (Art. 6(1)(f)) |
We do not sell personal data, use it for advertising, or process payment card data (payments are handled by Shopify).
2. Where data is stored
All invoice data and archives are stored exclusively on servers in the European Union. Backups are encrypted (AES-256 at rest, TLS 1.2+ in transit).
3. International access (important notice)
Our support team operates from China. Support access to personal data is: (a) disabled by default — personal data in our support tools is masked; (b) only unmasked for a specific ticket with your consent, logged and time-limited. Such access constitutes a third-country transfer safeguarded by the EU Standard Contractual Clauses (Module 2) incorporated in our DPA, together with the technical measures above.
4. Subprocessors
| Subprocessor | Role | Location |
|---|---|---|
| EU hosting provider (to be announced before launch) | Hosting & storage | EU |
| Cloudflare, Inc. | DNS, CDN, email routing | EU/Global |
| Shopify International Ltd. | Platform, billing | EU/Global |
| Peppol access point partner (when enabled) | E-invoice transmission | EU |
We will update this list and notify merchants of changes via the app.
5. Retention
Invoice archives: for the statutory retention period of the respective country (e.g. 8 years for German invoices, 10 years for French) or until you delete them, whichever you configure. Upon app uninstallation we honour Shopify's GDPR webhooks: shop data is deleted within 48 hours of the redaction request issued by Shopify, except where continued storage was explicitly agreed for archive export (max. 60 days). Technical logs: max. 90 days.
6. Your rights (and your customers' rights)
Under GDPR: access, rectification, erasure, restriction, portability, objection, and complaint to a supervisory authority. Customer requests should be directed to the merchant (controller); we support merchants in fulfilling them within the timelines of Art. 28 GDPR.
7. Contact
Privacy inquiries: [email protected] (subject "Privacy"). We respond within 30 days.