Who we are
Klirry is operated by Per Philip Alexander Hjelmberg, a sole proprietorship (enskild firma), Drottninggatan 12, 352 29 Växjö, Sweden, Swedish VAT number SE850529273301. The firm is run by its founder alone. The firm is the controller for the data described in this Policy.
Privacy contact: privacy@klirry.com.
We are established in Sweden, so our lead supervisory authority is the Swedish Authority for Privacy Protection (IMY, Integritetsskyddsmyndigheten), imy.se. For cookies and similar technologies the supervisory authority in Sweden is the Swedish Post and Telecom Authority (PTS). We have not appointed a data protection officer: Klirry is a one-person business that does not monitor individuals on a large scale or process special categories of data on a large scale (GDPR Art. 37).
Our two roles
Klirry processes personal data in two distinct capacities, and this Policy covers only the first.
| Role | Data | Governed by |
|---|---|---|
| Controller | Account and user data, security and audit records, email delivery records, trial reminders and notices, newsletter, billing and invoice records, acceptance evidence, website analytics (with consent), product analytics, support, affiliates | This Policy |
| Processor | Order records and other data imported from your store, payment and shipping files and advertising accounts, and everything derived from them | The Data Processing Agreement between Klirry and the merchant |
Where Klirry is a processor, the merchant is the controller and the merchant's own privacy notice governs. We act only on the merchant's documented instructions.
1. Data we process as controller
1a. Account and user data
| Field | Purpose | Note |
|---|---|---|
| Work email address | Login identifier, service communications | |
| Password | Authentication | argon2id hash only; the password itself is never stored |
| Role (owner / member) | Access control | |
| Two-factor secret | Two-factor authentication, where enabled | encrypted at rest (AES-256-GCM) |
| Email verification state | Confirms the address is reachable | |
| Last login timestamp | Security and account support | |
| Session records | Keeping you signed in | |
| Invitation records | Inviting colleagues | token stored hashed, with an expiry |
| Company details | Knowing who the business customer is | company name, address and what the business does, given at signup |
An email address is required to hold a Klirry account — it is the login identifier and the only way we can reach you about the service. Klirry does not ask for a personal identity number; for a sole trader the organisation number can be a personal identity number, and we then treat it as such (masked in the admin view, kept out of logs and error reports).
1b. Security, audit and operational records
We keep an audit log of security-relevant actions: the action type, the acting user's identifier, the affected object and a timestamp. It carries no free-text personal data. When an account is deleted the log is kept for 6 months with all user identifiers pseudonymised (section 6). Support access by the founder (opening your account to help you) is recorded in the same log.
We log transactional email delivery: category, template, subject line, provider message identifier, delivery state and any bounce or error.
We record application errors and performance data for diagnosis. Error reports are filtered so that they do not carry personal data, including Swedish personal identity numbers.
1c. Billing, invoices and acceptance of the terms
- Subscriptions paid by card. Payment is collected by Stripe on its hosted page; card details never reach us. We receive the billing contact name and email, company name, billing country, VAT number, plan and payment status.
- Subscriptions paid through Shopify. Shopify charges you; we receive the shop, plan and charge status, and the payout report.
- VAT evidence. To decide the VAT treatment we check your VAT number in the EU VIES service and keep the result, the date and the location evidence (billing country, card country) with the invoice.
- Invoices are kept as accounting records (section 6).
- Acceptance of the terms. We keep the version of the terms, the time, the account, the accepting user and the method, as proof of the agreement.
- Trial abuse. To stop repeated free trials we keep a keyed one-way identifier (HMAC) derived from signup details. It is pseudonymised, not anonymous; it is kept for 12 months. It blocks a second free trial only when the earlier trial was never paid: a returning paying customer is never blocked.
1d. Website visitors, newsletter and cookies
Visitors to klirry.com are not tracked unless they agree: website analytics runs only after consent (section 8). If you subscribe to the newsletter we keep your email address and the time you confirmed it (double opt-in). Marketing mail is sent only to people who have opted in, through a separate provider (section 4).
1e. Trial reminders, notices and invitations
During and after the trial we email the account's users: reminders before the trial ends and when it has ended, a notice before an unpaid account is deleted, notices of changes to the terms or to our sub-processors, and invitations to testers that the founder issues personally. These are service messages tied to your account, not marketing.
1f. Product usage, surveys and support
We record a small set of first-party events about how an account moves through Klirry (for example the steps of onboarding), optional survey answers and an optional reason when you cancel, and an internal health indicator for the account. These contain no free-text tracking of individuals beyond what you type into a survey or cancellation answer. Support correspondence is kept in the support mailbox, and the founder may log the time spent on an account.
1g. Affiliates
If you apply as an affiliate partner (companies only), we keep the partner's company details, referral code, referred sign-ups and commission records.
2. Data we process as processor — order records
When you connect a store, we import order records. We do not import your customers' names, email addresses, postal addresses or telephone numbers.
We do import, per order: your store's own order identifier and order number, the order date, destination country, currency, gross amount, VAT amount, shipping charged, discount, payment method, shipping method, whether shipping was tracked, financial and fulfilment status, refunded amount, campaign parameters from the landing URL (utm_source, utm_medium, utm_campaign, utm_content), and two flags recording whether a Meta or Google click identifier was present. We also import order lines (product identifier, quantity, amounts), payment-provider settlement records and carrier invoice lines you upload, and advertising data (spend and performance per campaign and ad).
These records can still be personal data. The order identifier is a key you can look up in your own store to reach a named person. Data of this kind is pseudonymised, not anonymous, and remains within the scope of data protection law.
We store only a flag for Meta and Google click identifiers, never the identifiers themselves. For carrier tracking numbers we store only a keyed one-way HMAC (used to match carrier invoices to orders) for 180 days after the order date, never the number itself.
The full list is in Annex 1 of the Data Processing Agreement.
3. Why we process it, and on what basis
| Processing | Purpose | Legal basis |
|---|---|---|
| Account creation, login, session management | Providing the service to the merchant organisation | Art 6(1)(b) contract (for a sole trader the user is the contracting party); for staff of a business customer Art 6(1)(f), operating the service our customer contracted for |
| Two-factor authentication | Protecting accounts | Art 6(1)(f) — account security |
| Security and audit logging, support access log | Detecting and investigating misuse | Art 6(1)(f) — securing the service and its customers' data |
| Transactional email and delivery logging | Account, security and service messages | Art 6(1)(b) and 6(1)(f) — communicating about the service |
| Trial reminders, change notices, tester invitations | Telling you what you need to know about your account | Art 6(1)(b) and 6(1)(f) — service communication, not marketing |
| Newsletter | Marketing to people who opted in | Art 6(1)(a) consent; Marknadsföringslagen 19 § |
| Error and performance monitoring | Keeping the service working | Art 6(1)(f) — service reliability |
| Billing, invoices, VAT evidence | Invoicing, VAT compliance and statutory bookkeeping | Art 6(1)(b) and Art 6(1)(c) |
| Acceptance evidence | Proving the agreement in a legal claim | Art 6(1)(f) and Art 5(2) |
| Trial-abuse identifier | Preventing repeated free trials | Art 6(1)(f), legitimate interest (assessed) |
| Website analytics (Umami) | Understanding which pages are read | Art 6(1)(a) consent, given before the script loads |
| Product analytics, surveys, health indicator | Improving the product and supporting customers | Art 6(1)(f) |
| Affiliate programme | Paying commission to partner companies | Art 6(1)(b) contract; the referral cookie, if used, Art 6(1)(a) consent |
| Deletion records | Proving that deletion took place | Art 6(1)(c) and 6(1)(f) |
| Order records | On the merchant's instruction | Processor — the merchant's own basis applies |
Legitimate interest assessment. Where we rely on Art 6(1)(f) we have weighed our interest against yours. The data subjects are mainly our customers' own staff, who chose to use a business tool and can expect its use to be logged for security and support. We keep to the minimum needed (an audit entry carries action, actor, object and time only), do not sell data, do not use it for advertising and do not profile individuals. You can object at any time (section 7); we then weigh your reasons case by case. We have assessed the trial-abuse identifier and the retention periods in the same way.
Platform data. Data we receive from a platform you connect (Shopify, Meta, Google, TikTok and others) is used only to serve you. We never sell it, never use it across customers or for benchmarks, and never use it to train AI models.
4. Who else sees the data
4a. Vendors and tools
| Recipient | Role | Purpose | Location | Transfer outside the EU/EEA | Status |
|---|---|---|---|---|---|
| Hetzner Online GmbH | Processor for Klirry | Cloud hosting: servers, database, storage volumes and encrypted backups | Germany (Falkenstein) | None: stays in the EU/EEA | Engaged |
| Scaleway SAS | Processor for Klirry | Transactional email only: account, security, trial-reminder and notice mail (never marketing) | France (Paris, fr-par) | None: stays in the EU/EEA | Planned |
| Functional Software, Inc. (Sentry) | Processor for Klirry | Error monitoring and crash reporting | EU data location (de.sentry.io); the provider is a US company | United States: possible access by the US provider; EU standard contractual clauses in Sentry's data processing agreement (the EU–US Data Privacy Framework is also available but an appeal against it is pending at the EU Court of Justice) | Planned |
| Stripe | Klirry's own tool | Subscription billing for customers who do not pay through Shopify: hosted checkout and payment collection. Klirry is the controller of billing data; Stripe is not a sub-processor of the Customer's Order Data | Stripe's data processing agreement states that personal data is transferred to Stripe, LLC in the United States under its data transfer addendum | United States: Stripe's data transfer addendum (standard contractual clauses); EU–US Data Privacy Framework where Stripe is certified | Planned until live mode |
| Sendinblue SAS (Brevo) | Klirry's own tool | Newsletter and other marketing email, sent only to people who opted in (double opt-in). Klirry is the controller; Brevo is not a sub-processor of the Customer's Order Data | France / EU | None: stays in the EU/EEA | Planned |
| Umami (self-hosted) | Klirry's own tool | Website analytics for klirry.com marketing pages, only after the visitor's consent (see the cookie section of the Privacy Policy). Runs on Klirry's own server; no third party receives the data | Germany (Falkenstein), on Klirry's own Hetzner server | None: stays in the EU/EEA | Planned |
4b. Connected platforms (data sources you choose)
| Platform | Role | What Klirry reads or sends | Access | How you revoke access |
|---|---|---|---|---|
| Shopify | Source platform and payment channel. Shopify Inc. (Canada) and Shopify Commerce Singapore Pte. Ltd. are Klirry's counterparties under the Partner Program Agreement; the merchant contracts with Shopify International Limited (Ireland). Klirry reads orders and products with the scopes read_orders and read_products; Shopify is an independent controller of its own data and not a sub-processor of Klirry. | Orders and products (scopes read_orders and read_products). No customer name, email, address or phone is stored | Read-only | Uninstall the app in your Shopify admin, or disconnect it in Klirry under Settings, Connections (Klirry stops reading at once) |
| Meta | Source platform for ad spend and performance (permission ads_read). Meta is an independent controller; Klirry is not Meta's processor and Meta is not Klirry's sub-processor. | Ad spend and performance per ad account (permission ads_read) | Read-only | Remove Klirry from the connected apps in your Meta business settings, or disconnect it in Klirry under Settings, Connections (Klirry stops reading at once) |
| Source platform for Google Ads spend (planned) and Google Analytics 4 as a directional signal (planned, never in the profit figure). Google is an independent controller. | Google Ads spend and Google Analytics 4 sessions (both planned; never part of the profit figure) | Read-only | Remove Klirry from the third-party access of your Google account, or disconnect it in Klirry under Settings, Connections (Klirry stops reading at once) | |
| TikTok | Planned source platform for ad spend. Not connected today. TikTok is an independent controller. | Ad spend (planned; not connected today) | Read-only | Remove Klirry in your TikTok business settings, or disconnect it in Klirry under Settings, Connections (Klirry stops reading at once) |
| WooCommerce | Prepared, not offered to customers yet. Source platform: your own WooCommerce store, which you host. Klirry calls the store's REST API at the address you enter. The store owner is the controller; Klirry is not the store's processor and the store is not Klirry's sub-processor. | Orders and their line items from the store's REST API. No customer name, email, address or phone is stored | Read-only (a read key you create) | Delete the REST API key in WooCommerce (Settings, Advanced, REST API), or disconnect it in Klirry under Settings, Connections (Klirry stops reading at once) |
| PrestaShop | Prepared, not offered to customers yet. Source platform: your own PrestaShop shop, which you host. Klirry calls the shop's Webservice at the address you enter. The shop owner is the controller; Klirry is not the shop's processor. | Orders and their lines from the shop's Webservice. No customer name, email, address or phone is stored | Read-only (a Webservice key you create) | Delete the key under Advanced Parameters, Webservice in PrestaShop, or disconnect it in Klirry under Settings, Connections (Klirry stops reading at once) |
| Shopware 6 | Prepared, not offered to customers yet. Source platform: your own Shopware 6 shop. Klirry calls the shop's Admin API at the address you enter. The shop owner is the controller; Klirry is not the shop's processor. | Orders and their lines through a search request (a read; no change is ever sent). No customer name, email, address or phone is stored | Read-only (an integration you create) | Delete the integration under Settings, System, Integrations in Shopware, or disconnect it in Klirry under Settings, Connections (Klirry stops reading at once) |
| BigCommerce | Prepared, not offered to customers yet. Source platform. BigCommerce is an independent controller of its own data; Klirry is not its processor and BigCommerce is not Klirry's sub-processor. | Orders (v2 REST API). No customer name, email, address or phone is stored | Read-only (a store-level API account with Orders read-only scope) | Delete the API account in your BigCommerce store, or disconnect it in Klirry under Settings, Connections (Klirry stops reading at once) |
| Wix | Prepared, not offered to customers yet. Source platform. Wix is an independent controller of its own data; Klirry is not its processor and Wix is not Klirry's sub-processor. | Orders (eCommerce Orders search, a read). No customer name, email, address or phone is stored | Read-only (an API key with the Read eCommerce Orders permission) | Delete the API key in your Wix account, or disconnect it in Klirry under Settings, Connections (Klirry stops reading at once) |
| Quickbutik | Prepared, not offered to customers yet. Source platform. Quickbutik is an independent controller of its own data; Klirry is not its processor and Quickbutik is not Klirry's sub-processor. | Orders through the store API (JSON GET only). No customer name, email, address or phone is stored | Read-only (the store API key you create) | Delete or regenerate the API key in your Quickbutik account, or disconnect it in Klirry under Settings, Connections (Klirry stops reading at once) |
| PayPal | Prepared, not offered to customers yet. Source of payment fees. PayPal is an independent controller of its own data; Klirry is not its processor and PayPal is not Klirry's sub-processor. | Transactions and their fees from the Transaction Search report. No payer name or email is stored | Read-only (a REST app you create with Transaction Search) | Delete the REST app in the PayPal developer dashboard, or disconnect it in Klirry under Settings, Connections (Klirry stops reading at once) |
| Stripe (your own Stripe account) | Prepared, not offered to customers yet. Source of payment fees from the Stripe account YOU hold with Stripe. This is a different relationship from Klirry's own use of Stripe to bill its customers (see the vendor list): here Stripe is an independent controller of your account data and Klirry only reads it. | Charges and balance transactions, to learn the real fees. No cardholder or customer detail is stored | Read-only (a restricted key with Charges: Read and Balance Transactions: Read) | Delete the restricted key in your Stripe dashboard (Developers, API keys), or disconnect it in Klirry under Settings, Connections (Klirry stops reading at once) |
| Slack (your own workspace) | A destination YOU choose: if you paste an incoming-webhook URL of your own Slack workspace, Klirry posts alerts there in addition to email. Klirry has no Slack workspace of its own that receives customer data. Slack is an independent controller of the messages in your workspace; it is not a sub-processor of Klirry. | Nothing is read. Klirry sends the decision sentence of an alert email and a link to the decisions page, to the webhook you set up | Send only, to your own webhook | Delete the incoming webhook in Slack, or remove the Slack address in Klirry under Settings |
We do not sell personal data and we do not use it for advertising.
5. Where data is processed, and transfers
Our database and application run on infrastructure located in Germany. Email delivery uses a French provider. Two vendors involve the United States: Stripe (billing; Stripe's data processing agreement and data transfer addendum, based on standard contractual clauses and, where Stripe is certified, the EU–US Data Privacy Framework) and Sentry (error monitoring on an EU data location, operated by a US company; standard contractual clauses). The EU–US Data Privacy Framework is in force, but an appeal against it is pending at the EU Court of Justice, so we rely on standard contractual clauses as well. No other transfer outside the EU/EEA takes place. The table in section 4 is generated from the same register as the public sub-processor page.
6. How long we keep it
| Data | Retention | Legal basis |
|---|---|---|
| Customer data while the account exists (orders, order lines, ad spend, costs, connections, users, settings, reports) | For as long as the account exists | Contract; for Order Data the Customer's instruction as controller (GDPR Art. 28) |
| Customer data after cancellation, after a trial that is never paid, or after a pause for non-payment | Retrieval period with full JSON/CSV export, then hard deletion confirmed by email: after cancellation at least 30 days; after a trial that is never paid 30 days from the trial end (day 51 after the account was opened); after a pause for non-payment 60 days from the pause (day 7 after the first failed payment) | EU Data Act Art. 25(2); GDPR Art. 28(3)(g) |
| Shopify store data after the app is uninstalled (shop/redact) | Deleted within 30 days of the redact request | Shopify API Terms 6.2.3 |
| Own invoices, credit notes and accounting records, including the VIES result and the location evidence behind each invoice | 7 years after the end of the financial year | Bokföringslagen (1999:1078) 7 kap. 2 §; GDPR Art. 6(1)(c) and 17(3)(b) |
| VAT records for the One-Stop Shop (OSS) scheme | 10 years after the end of the transaction year | Mervärdesskattelagen (2023:200); GDPR Art. 6(1)(c) |
| Acceptance evidence: terms version, time, account, accepting user, acceptance method | 10 years from the acceptance (the general limitation period), pseudonymised once the account is deleted | GDPR Art. 6(1)(f) and 5(2): proof of the agreement in a legal claim |
| Audit log of security-relevant actions | While the account exists; after deletion 6 months, pseudonymised, then deleted | GDPR Art. 6(1)(f): security, fraud prevention, legal claims |
| Keyed HMAC identifier used to detect trial abuse (not reversible without the key; pseudonymised, not anonymous). It blocks a second trial only when the earlier trial was never paid | 12 months from the first trial start | GDPR Art. 6(1)(f): preventing repeated free trials |
| Support correspondence (emails between a customer and Klirry support) | 12 months after the last message in the conversation | GDPR Art. 6(1)(f): answering follow-up questions and defending a claim; deleted after that |
| Email suppression list (an address that bounced, complained or unsubscribed; the address only, with no link to an account) | No fixed end: kept so the address is never mailed again, until the owner asks for removal | GDPR Art. 6(1)(f); ePrivacy and Marknadsföringslagen (2008:486) 19 § |
| Deletion certificates (date and row counts, with a hash in place of the account) | 3 years | GDPR Art. 5(2) and 17: proof that deletion took place |
| Meta data deletion requests (random confirmation code, a keyed hash of Meta's user id, status and dates; no name or email) | 3 years | GDPR Art. 5(2) and 17: proof that the deletion Meta forwarded took place |
| Queued transactional mail jobs in the job queue (recipient address and the values filled into the message) | A sent mail: 1 hour, and the values are cleared the moment it is sent. A mail that failed for good: the values are cleared at the last attempt and the job is kept at most 7 days | GDPR Art. 6(1)(b) and (f): delivering the message and diagnosing a failed delivery |
| Keyed HMAC of a carrier tracking number on an order | 180 days after the order date | Processor: Customer's instruction (carrier invoice matching) |
| Newsletter subscriptions | Until unsubscribe; an unsubscribed address stays on the suppression list; an unconfirmed subscription is deleted after 30 days | GDPR Art. 6(1)(a) consent; Marknadsföringslagen 19 § |
| Website analytics (only after the visitor's consent) | 13 months | GDPR Art. 6(1)(a) consent; ePrivacy |
| Error reports (Sentry) | At most 30 days | GDPR Art. 6(1)(f): keeping the service working |
| Encrypted database backups | Pre-release dumps: 14 days. A nightly off-site copy is not yet in operation and will keep at most 30 days. Deleted data drops out of backups within that time | GDPR Art. 32: availability and recovery |
| The record of a deletion request (status and the address the confirmation was sent to) | 7 days after the deletion is confirmed by email; the proof that lasts is the deletion certificate (3 years, no personal data) | GDPR Art. 6(1)(f): showing the customer that the deletion ran |
| Password-reset, email-verification and invitation tokens (hashed; an invitation also holds the invitee email address), and the sign-in links and sessions of affiliate partners (hashed) | 7 days after the token expired or was used | GDPR Art. 6(1)(f): security of sign-in and answering "my link expired" questions |
| Log of the events Stripe sent (event id, type, a payload stripped of personal data), used to ignore duplicates | 90 days after receipt | GDPR Art. 6(1)(f): processing each billing event once and diagnosing failures |
| A referral click on a partner link that no signup followed (partner and time only; no visitor identifier) | 120 days after the click. A click that led to a signup becomes an anonymous count for the partner once the account is deleted | GDPR Art. 6(1)(f) and Art. 5(1)(e): crediting a partner inside the 90-day attribution window |
| Contact details of an affiliate partner (name or label, contact address, payout method) | While the partner agreement runs; erased 12 months after the partner was suspended or, if never activated, after the last change. Payout records follow the invoices row | GDPR Art. 6(1)(b) the partner agreement; Art. 6(1)(f) the fraud-review period afterwards |
| Background jobs that failed for good (tenant and connection ids and the error text), kept for inspection | 30 days after the failure (mail jobs: at most 7 days, see the mail queue row) | GDPR Art. 6(1)(f): diagnosing and replaying a failed job |
| IP address inside a rate-limit counter key (Redis), to slow down abuse of sign-in and the API | 2 minutes after the last request; counters for second-factor attempts 30 minutes | GDPR Art. 6(1)(f): protecting accounts against guessing |
| Application and proxy logs on the server (request path, status, timing; secrets and personal data are scrubbed before logging) | Rotated by size, not by time: at most 250 MB per container and 1 GB of host journal; older lines are overwritten. Error detail beyond that lives in error monitoring (30 days) | GDPR Art. 6(1)(f) and Art. 32: operating and securing the service |
When you cancel you have a retrieval period of at least 30 days with full export. A trial that is never paid is deleted on day 51 after the account was opened (30 days after the trial ends), and an account paused for non-payment after 60 days from the pause; the export is open the whole time and we email you before the deletion. After the retrieval period we delete everything except the rows in this table, and we confirm the deletion by email. Deletion runs table by table and a verification step confirms nothing else remains.
7. Your rights
You have the right to access your data, to have it corrected, to have it erased, to restrict processing, to receive it in a portable form, and to object to processing based on legitimate interests. Where processing rests on consent, you may withdraw it at any time without affecting what was done before.
You can export your data ("Export your data" in Settings) and request deletion by closing your account ("Close account" in Settings → Billing) in the application, or write to privacy@klirry.com. For users who came through Meta, the deletion instructions are on klirry.com/legal/data-deletion.
We answer within one month of receiving a request. Where a request is complex, or where there are several, we may extend by a further two months and will tell you within the first month if we do.
If your request concerns order records, the merchant whose store the order came from is the controller — we act only as their processor and cannot respond to end consumers directly. Send the request to them; we will assist them. We do not hold your name, email address, postal address or phone number in the first place.
You may complain to IMY, or to the supervisory authority where you live or work.
8. Cookies and local storage
The table below is the complete inventory.
| Item | Kind | Purpose | Duration | Consent needed? |
|---|---|---|---|---|
klirry_session | Cookie, first party, httpOnly | Keeps you signed in | 30 days (24 hours for the founder) | No — strictly necessary |
klirry_claim | Cookie, first party, httpOnly, limited to one path | Lets the browser that installed the Shopify app claim the new connection | 1 hour | No — strictly necessary |
| UI-state keys in browser storage | localStorage / sessionStorage | Remembers a dismissed banner, onboarding progress and a chosen tab or filter (signed-in application only). The language comes from the address you opened, not from stored data | Until cleared | No — strictly necessary, triggered by you |
| Consent choice | localStorage | Remembers your cookie choice | Until cleared | No — it records your choice |
| Website analytics (Umami) | Script, first-party address, no cookie | Counts page views of klirry.com pages | Data kept 13 months | Yes, before the script loads |
klirry_ref | Cookie | Credits an affiliate partner for a sign-up | 90 days | Yes — and not set today (affiliate programme off) |
klirry_tref | Cookie | Remembers which customer's referral link you followed, so that customer can be credited when you sign up and pay | 90 days | Yes and not set today (customer referral programme off) |
klirry_partner | Cookie | Keeps an affiliate partner signed in to the partner dashboard (only after the partner opened an emailed sign-in link) | 24 hours | No — strictly necessary (sign-in); not set today (affiliate programme off) |
We load no advertising cookie, no social-media pixel and no third-party tracker. Strictly necessary storage needs no consent; everything else waits for your choice, and "reject" is as easy as "accept".
9. Automated decision-making
Klirry calculates profit and classifies the performance of advertisements, products, countries, payment methods and shipping, and presents recommendations. These are decisions about business operations, not about people, and they produce no legal or similarly significant effect on any individual. No solely automated decision-making within the meaning of Article 22 takes place.
10. Changes to this Policy
We post any change here and update the date below. A material change is announced by email to account holders at least 30 days before it takes effect.
Changelog
Each entry names the version, the date it was written, and what changed. A change of the major version number is a material change: it is announced to customers by email at least 30 days before it takes effect.
| Version | Date | Change |
|---|---|---|
| 1.0 | 2026-10-10 | First published version. |
| 1.1 | 2026-10-11 | Retention table completed with new classes (mail-queue jobs, deletion-request records, tokens and partner sessions, Stripe event log, referral clicks, partner contact details, failed jobs, rate-limit counters, server logs, Meta deletion requests); connected platforms (4b) extended; cookie klirry_partner added. Minor change: no customer is in live mode yet, no sub-processor is added, and periods only get shorter or are new classes, so there is no 30-day notice. Editorial change (no version bump): the in-app label quoted in the section on your rights is now "Close account" (was "Cancel account"); it no longer cancels a plan only but closes the account, and asks for the account name and password. What is processed, why and for how long is unchanged. |