Privacy Policy - Size Chart and Guide by Jotly

1. Introduction and Scope

This Privacy Policy explains how Jotly ("Jotly", "we", "us") handles data in connection with the Size Chart and Guide by Jotly application ("the App") when it is installed on a Shopify store. "You" and "Merchant" refer to the store that installs the App and the people who use it on the store's behalf.

The App displays size charts and size guides on product pages. It does not collect information that directly identifies the customers who visit your store (your "End Customers"). It uses limited, pseudonymous analytics, described in Section 3.

By installing or using the App, you agree to our Terms and Conditions. The Terms and this Privacy Policy together form the agreement between you and Jotly. If you do not agree to them, please do not install or use the App.

This policy is written with the data protection laws that may apply to you in mind, including the EU and UK General Data Protection Regulation (GDPR), the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA), and India's Digital Personal Data Protection Act, 2023.

Our role. For the Merchant account data described in Section 4, Jotly decides how the data is used and acts as the controller (a "data fiduciary" under Indian law). For the storefront analytics described in Section 3, Jotly processes data on the Merchant's behalf in order to provide the Merchant with size chart statistics.

2. Who This Policy Covers

2.1 Merchants

Merchants are the Shopify stores that install the App, and the store owners and staff who use the App's admin dashboard to create and manage size charts. Section 4 describes the data we handle about them.

2.2 End Customers

End Customers are people who browse a Merchant's store. When they view a product page, the App displays the size chart the Merchant configured. The App does not collect their names, email addresses or other details that directly identify them. Section 3 describes the limited analytics data involved.

3. End Customer Data

What we do not collect. The App does not collect End Customers' names, email addresses, phone numbers, postal addresses, customer account identifiers, order details or payment information, and it does not set cookies.

Anonymous visitor ID. To count unique viewers, the App creates a random identifier. It is stored in the visitor's browser (local storage) only where the visitor's privacy choice, as reported by Shopify's Customer Privacy API, allows analytics. Where it does not, the identifier exists only in memory for that page view and nothing is stored on the visitor's device. The identifier is not linked to any name, email address or customer account.

Last viewed size chart. To show Merchants whether customers who viewed a size chart then added the product to their cart, the App remembers which size chart was viewed for a product. The same rule applies: it is stored in the browser only where analytics is allowed, and otherwise kept in memory for the page view only. If a visitor later withdraws consent, the stored values are removed.

Size chart events. When a visitor opens a size chart, or adds a product to the cart after viewing one, the App sends an event to our analytics service containing: the visitor ID described above, the device category (desktop or mobile), the store domain, the size chart ID, the page type, handle, title and URL path, the product ID, the page language and whether the store's live or preview theme was used. This data is used to give Merchants aggregate statistics about their size charts and to monitor the App's performance. It is not sold, not used for advertising and not used to build profiles of individuals.

IP addresses. Our analytics records do not include End Customer IP addresses. As with any website, IP addresses are processed by our hosting and network providers when a request is delivered, and may appear in their short-term security and operational logs.

Some laws, including the GDPR, may treat a random online identifier as personal data even though it does not reveal who someone is. We treat the visitor ID accordingly: it is pseudonymous, used only for the purposes above, and deleted along with other analytics data in line with our retention practices.

Merchant-enabled integrations. If a Merchant turns on the optional Google Analytics or Meta (Facebook) Pixel integrations, the App passes size chart events to those tools on the Merchant's behalf. These integrations are off by default and are governed by the Merchant's own setup and privacy notice, and by Google's and Meta's terms. Jotly does not receive the data those tools collect.

Your responsibilities as a Merchant. Because the App follows the visitor's choice through Shopify's Customer Privacy API, it works with Shopify's cookie banner and other consent tools that use that API. You remain responsible for your store's own privacy notice and consent setup. We recommend that your privacy notice mentions that your store uses size chart analytics.

4. Merchant Data

We handle the following data about Merchants:

Store details: the store's name and domains, plan and configuration, received from Shopify, so that the App works for the right store.
Contact details: the name and email address of the store owner or staff member using the App, received from Shopify, used for support, billing, account and service messages.
Store content: the size charts, settings, images and other content you create in the App.
Admin usage data: records of actions in the admin dashboard (for example when a size chart is created or edited), and recordings of how admin pages are used (clicks, scrolling and pages visited), linked to the store and the user's name and email, to help us provide support and improve the App.
Content you send us: support messages, feature requests and review feedback.
Text sent for AI translation: when you use AI translation, the size chart text you choose to translate is sent to an AI provider (see Section 6). Please do not put personal data in size charts you translate.
Security logs: records of requests made to the App, including the store, the resource requested and the time, used to detect and prevent misuse.

5. Why We Use Merchant Data (Legal Basis)

To provide the App (contract): running the App, rendering size charts, billing, support and service messages.
Our legitimate interests: keeping the App secure, preventing misuse and enforcing our Terms, understanding how the App is used, and improving it. We have balanced these interests against your rights and consider them proportionate.
Legal obligations: where we need to keep or disclose data by law, for example for tax and accounting.

6. Service Providers

We use the following service providers to run the App. They process data only as needed to provide their services to us:

Shopify: the platform the App runs on.
DigitalOcean: application hosting and database.
Cloudflare: storefront analytics, file storage, content delivery and network security.
Tawk.to: the in-app support chat.
Microsoft Clarity: recordings and analytics of how the App's admin pages are used.
Google: AI translation of size chart text you choose to translate.
Slack: internal operational alerts, which may include a store's domain.

We also respond to Shopify's mandatory privacy webhooks for apps. See Shopify's privacy requirements for apps.

7. Security

We use reasonable technical and organisational measures to protect the data we hold, including encryption in transit (TLS), access to production systems limited to authorized people, and the security features of our hosting providers. We also monitor requests to the App to detect and prevent unauthorized access and other breaches of our Terms, as described in Section 4. No system is completely secure, and we cannot guarantee absolute security.

8. Retention and Deletion

While the App is installed: we keep Merchant data for as long as it is needed to provide the App.

Personal data after uninstalling: within 48 hours of the App being uninstalled, we delete the personal data associated with your store that we hold, including feature requests and review feedback. Our service providers delete data they hold in line with their own retention practices.

Store content after uninstalling: size charts, settings and other non-personal content ("Store Content") may be deleted after the App is uninstalled. We do not guarantee that Store Content will be kept for any period, or that it can be restored if you reinstall the App. Please export anything you want to keep before uninstalling.

Security and legal records: we may keep limited records for longer where needed to prevent misuse, enforce our Terms, resolve disputes or meet legal obligations such as tax and accounting rules.

Analytics data: size chart events are kept in aggregate form for as long as they are useful for Merchant statistics.

9. International Data Transfers

Data may be processed outside your country, including in the United States and in the other countries where our service providers operate. Where data is transferred from the European Economic Area, the United Kingdom or Switzerland, we rely on the safeguards our providers offer, such as adequacy decisions and Standard Contractual Clauses.

10. Your Rights

Depending on where you are, you may have the right to:

ask what personal data we hold about you and receive a copy of it;
ask us to correct inaccurate personal data;
ask us to delete your personal data, which you can also do by uninstalling the App (see Section 8);
receive your personal data in a structured, machine-readable format;
object to processing based on our legitimate interests (we will stop unless we have compelling legitimate grounds to continue, such as security and preventing misuse); and
complain to your local data protection authority.

These rights apply to personal data. Store Content is not personal data and is handled as described in Section 8. We may need to verify your identity before acting on a request.

11. Contact and Grievances

For questions about this policy, to exercise your rights or to raise a grievance about how your data is handled, contact our Grievance Officer at support@jotly.live with the subject line "Privacy". We aim to acknowledge requests within 2 to 3 business days and to resolve them within 30 days.

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