Privacy and cookies policy

Last updated March 2024.

Previous version (January 2021)

We respect your privacy and are committed to protecting your personal data. This policy explains the terms on which we collect and process your personal data, and how we protect your personal data when you visit our website at https://cloudshelf.ai/, you subscribe to use “Cloudshelf”, our online SaaS platform, you make a purchase from a retailer that subscribes to Cloudshelf, or you otherwise engage with us. In addition, it explains your privacy rights and how the law protects you.

For the most part, we will collect personal data of retailers that subscribe to Cloudshelf (and their staff) and those that contact us. It is, however, important to understand that for those that make a purchase from a retailer that subscribes to Cloudshelf, we will record your email and/or phone number and pass it to the retailer, but we don’t store these. We will also store a reference to a basket and the contents of that basket, but the connection between you and the basket is between you and the retailer.

1. Who we are

We are Cloudshelf Limited, a company registered in England and Wales under company number 13158083 with our registered office at 36-38 Cornhill, London, United Kingdom, EC3V 3NG (“we”, “us” or “our”). We are the controller responsible for your personal data.

We comply with “data protection laws”, which means the Data Protection Act 2018, the EU law retained version of the General Data Protection Regulation (EU) (2016/679), the California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act (“CPRA”).

We are registered with the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (ico.org.uk), and our registration number is ZB262450. If you have any concerns about data protection, we would appreciate if you contacted us first so we can discuss these with you before you approach the ICO. You can reach us at dpo@cloudshelf.ai.  

2. The data we may collect about you

Personal data/information means any information about an individual from which that person can be identified. It doesn’t include anonymous data.

By way of a summary, we have grouped together the various types of personal data that we may collect, use, store and transfer, as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, your job title, and your likeness (via any profile pictures).
• Contact Data includes billing address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of the services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website.
• Profile Data includes your username and password (if applicable), purchases or orders made by you, your interests, preferences, feedback, and survey responses. 
• Usage Data includes information about how you use our website and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Aggregated Data such as statistical or demographic data for any purpose, isn’t considered personal data in law as this data will not directly or indirectly reveal your identity to us. We may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

We don’t automatically collect any other Special Categories of Personal Data about you. This includes details about your race or ethnicity, religious or philosophical beliefs, health, sex life, sexual orientation, political opinions, trade union membership, genetic and biometric data. We also don’t collect any information about criminal convictions and offences.

We may provide you with the option to register with us via your existing eCommerce Accounts. If you choose to register with us in this way, we will collect the personal data described in clause 3 of this policy.

3. How is your personal data collected?

We may use different methods to collect data from and about you including through:

• Integration with Cloudshelf. Through Cloudshelf you (as a retailer) can connect to your eCommerce accounts, such as Shopify and  Salesforce Commerce Cloud (“eCommerce Accounts”) by allowing us access to them via the API key and token. When you let us access your eCommerce Accounts, we may pull in the content you have stored in your eCommerce Accounts and have authorised us to pull through to make it available via Cloudshelf. For more information, please refer to our terms and conditions at https://cloudshelf.ai/terms-and-conditions
• Direct interactions. You may give us your Identity Data and Contact Data by filling in forms or by corresponding or engaging with us by post, phone, email, social media or otherwise.
• Automated technologies or interactions. As you interact with our website and Cloudshelf, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources, such as Google, Companies House, the electoral register, or social media.

When you (as a shopper) want to buy a product from a retailer that subscribes to Cloudshelf, we instruct the retailer’s eCommerce platforms to create a basket using their existing eCommerce platform customer and payment infrastructure. You enter your details via a web page that we may provide, storing your details in the retailer’s existing data infrastructure. Cloudshelf has no visibility of this personal data once the transaction is complete, and only knows that a transaction was offered. By default, your payments will be processed through the retailer’s existing payment gateway and providers, and so we do not see, store or process any Financial Data.

4. How we use your personal data

We will only use your personal data when we can rely on a legitimate (lawful) basis, such as:

• Contract: Where we need to perform the contract, we are about to enter into or have entered into with you.
• Legitimate Interests: Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Legal Obligation: Where we need to comply with a legal obligation.

5. Purposes for which we will use your personal data

We have set out below the ways we may use your personal data, and which of the legitimate bases we rely on to do so:

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6. Marketing

You may receive marketing communications from us if you have requested information from us or purchased services from us and you haven’t opted out of receiving that marketing. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

7. Cookies

Our website uses cookies in accordance with the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 and data protection laws to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
•  Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Our website also uses Google Analytics. Google Analytics is a web analytics service provided by Google that tracks and reports website traffic. This service uses cookies to collect information about how users interact with our website, providing us insight on how many users are visiting our website, which pages they visit, how long they stay on our website, and where they are coming from (for example, from a search engine, direct link, or referral from another website). This information helps us understand our audience and improve our website to enhance user experience.

Please note that third parties may also use cookies, over which we have no control. These named third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third-party cookies are likely to be analytical cookies or performance cookies or targeting cookie.

Browser cookie controls

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

Information about how to configure your browser to block cookies can be found at:

• Google Chrome
• Microsoft Edge
• Internet Explorer
• Firefox
• Safari
• Safari Mobile
• Opera

8. Disclosures of your personal data

We may disclose your information in the following cases:

• If we want to sell our business, or our company, we can disclose it to the potential buyer
• We can disclose it to other businesses in our group, as defined in the UK Companies Act 2006
• We can disclose it if we have a legal obligation to do so, or in order to protect other people’s property, safety, or rights
• We can exchange information with others to protect against fraud or credit risks.

We use a variety of third party services (sub-processors) as part of our business activities and you/we will therefore share your personal data with these sub-processors. The types of sub-processors we might use fall into different categories, as follows:

• Credit card processing services
• Order fulfilment service providers
• Analytics service providers
• Event/campaign management service providers
• Website management service providers
• Information technology and related infrastructure provision
• Email delivery services
• Our auditors and legal advisors.

In particular, we use the following key sub-processors and you can view their privacy policies by linking the links:

• Google
• Microsoft Azure
• HubSpot
• Sentry

It is important to note that all third parties and sub-processors are bound by data protection obligations and, in the case of any third parties we sub-contract our services to, we will enter into a contract with them with comprehensive data protection obligations to ensure the security of your personal data.

For retail eCommerce platforms like Shopify and Salesforce, while we integrate Cloudshelf with your eCommerce Accounts, you (as retailer) directly manages those eCommerce Accounts and you are therefore responsible for the personal data stored within them. As such, you should review the data processing and privacy practices of these eCommerce platforms.

9. Data security

We take data security seriously, employing robust physical, electronic, and managerial safeguards. Access to your personal information is restricted to those with legitimate business needs, ensuring confidentiality and integrity.

In line with our high security standards, we're pursuing SOC2 certification and practice data minimisation, retaining only necessary personal data. In case of a data breach, we'll promptly inform you and necessary authorities, striving to mitigate impacts. For detailed security practices and data handling policies, please refer to https://trust.cloudshelf.ai/.

10. International transfers

We may transfer your personal data outside of the UK or the European Economic Area (EEA) where we engage third parties to provide services on our behalf, such as to receive services or deal with payment. Whenever we transfer your personal data out of the UK or the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data
• where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

 Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or the EEA.

11. Data retention

We prioritise minimising the personal data we collect, retaining only what's necessary. Your personal and customer data will be removed as soon as it's no longer needed, with specific retention periods based on legal and operational requirements. If you (as a retailer) disconnect your eCommerce Accounts from Cloudshelf , we will erase all associated data after 48 hours, though usage records and account names will be maintained. This approach ensures your data is handled securely and in compliance with applicable laws.

12. Children’s Personal Data

Our website isn’t intended for use by children under the age of 18, and we don’t knowingly collect personal data from children under the age of 18. If we become aware that we have collected personal data from a child under the age of 18, we will promptly delete that data. If you believe we have collected personal data from a child under 18, please contact us.

13. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us by emailing us at dpo@cloudshelf.ai.

You won’t have to pay a fee to access your personal data (or to exercise any of the other rights), but we can charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive, or we can refuse to comply in these circumstances.

We may need you to provide evidence of your identity as a security measure and we may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month, but it could take longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

14. Notice for California residents of privacy practices and rights

If you are a California resident, the CCPA grants you specific rights regarding your personal information. This section describes your CCPA rights and how to exercise those rights.

Right to Know and Access

You have the right to request that we disclose certain information to you about our collection and use of your personal data over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal data we collected about you.
• The categories of sources for the personal data we collected about you.
• Our business or commercial purpose for collecting or selling that personal data.
• The categories of third parties with whom we share that personal data.
• The specific pieces of personal data we collected about you (also called a data portability request).

Right to Delete

You have the right to request that we delete any of your personal data that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal data from our records, unless an exception applies.

Right to Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Do Not Sell My Personal Data

We do not sell your personal data. However, if in the future we decide to sell personal data, we will update this privacy policy to inform you of your right to opt-out of the sale of your personal data.

Exercising Your CCPA Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by contacting us.

Only you, or someone legally authorised to act on your behalf, may make a verifiable consumer request related to your personal data. We may only respond to two verifiable consumer requests per consumer per 12-month period.

15. Third party links

This policy only relates to our website and our business. We might have links on/within our services to other websites, and these websites will have their own terms and conditions and privacy policies. You should check those privacy policies before providing your personal data to those websites.

16. Changes to this policy

We can update this policy from time to time as laws change or as our website, Cloudshelf, or our services change. If we make material changes to this policy, and we need your consent to those changes, we will contact you by email to do so.