happywards — Privacy Policy

Last updated: 26 August 2026

1. Who this covers, and who is responsible for what

happywards is a loyalty-points and product-reviews app that a merchant installs on their Shopify store. There are two relationships here and they carry different obligations.

happywards is operated by a single founder-operator. Contact details are in §10.

2. What we collect, and where it comes from

This is the complete list. If a field is not named here, we do not hold it.

About shoppers, received from Shopify

About shoppers, generated by happywards

About shoppers, given to us directly by them

What we deliberately do not collect

3. Why we process it, and the legal basis

We process shopper data only on the merchant’s instructions. The merchant is responsible for having a lawful basis; these are the bases that ordinarily apply.

We do not sell personal information and we do not share it for cross-context behavioural advertising, as those terms are used in the CCPA/CPRA and comparable US state laws. There is nothing to opt out of because there is no such sharing.

4. Who we share it with

We disclose data to no one else. We would disclose it if compelled by law, and we would tell the affected merchant unless legally prohibited from doing so.

5. Where it is processed, and international transfers

All processing happens in the United States, in DigitalOcean’s sfo2 region (San Francisco). There is no second region and no processing anywhere else.

For merchants and shoppers in the EEA, the UK or Switzerland this is a transfer out of your jurisdiction. Transfers are made under the European Commission’s Standard Contractual Clauses together with the UK International Data Transfer Addendum. A copy is available on request from privacy@happywards.com.

6. How long we keep it

7. Your rights

In the EEA or the UK you have the right to access your data, to have it corrected or erased, to restrict or object to processing, to data portability, and to complain to your supervisory authority. In California and comparable US states you have the right to know, to delete, to correct, to opt out of sale or sharing (there is none), and not to be discriminated against for exercising any of them.

Shoppers: ask the merchant whose store you bought from. They are the controller and they hold the deadline. Shopify relays the request to us automatically and we produce the merchant a complete export of everything we hold about you — member record, every ledger entry, every redemption, every review, every email we generated, and any unsubscribe record — plus a plain-language summary they can forward.

Retrieval of that export is a manual step for our operator today. A merchant who has received a subject-access request should email us and we will send them the artifact. We are stating the friction rather than hiding it: it is the honest description of a one-person operation, and automating it is on the roadmap.

Erasure is handled the same way: Shopify relays it, and we anonymise the member — email replaced, names removed, the Shopify customer id dropped, review author details redacted, and any queued email deleted. The points ledger survives in anonymised form because it contains no personal data (a signed number and a reason) and is the merchant’s financial record.

8. Security

Traffic is encrypted in transit. Every Shopify webhook is signature-verified before it is parsed. The public reviews API returns an allow-list of fields and never an author email or a member id. No personal data appears in a URL or query string. Secrets come from the environment and none is committed to source control. Access to production is held by one person with two-factor authentication everywhere.

What we do not have, stated here rather than buried: no SOC 2, no ISO 27001, no third-party penetration test, a single region with no failover, and no access log recording staff reads of member records.

9. Children

happywards is not directed at children and we do not knowingly process the data of anyone under 16. A shopper’s age is not something we hold or can check — the merchant controls who can join their programme. If you believe a child’s data is in the system, contact us and we will work with the merchant to remove it.

10. Contact

We have not appointed a Data Protection Officer, because Art. 37 does not require one here: we carry out no large-scale systematic monitoring and process no special-category data. Data protection questions go to privacy@happywards.com.

11. Changes to this policy

We will post the new version here with a new date and, for any change that materially affects what we do with personal data, notify merchants by email at least 30 days before it takes effect.