This is a draft, not legal advice. It sets out what the software actually does with data, which is the part only we can write. Have a lawyer review it before you rely on it, and fill in every bracketed placeholder.

Privacy

Last updated: [DATE] · Controller: [LEGAL ENTITY NAME], [ADDRESS]

Who this covers

Two different groups, with different relationships to us.

Merchants — the people who sign up for Attendant. We are the data controller for your account information.

Shoppers — people visiting a store that uses Attendant. For their data we are a processor acting on the merchant's instructions; the merchant is the controller. If you are a shopper wanting your data removed, contact the store you visited, and they can action it through us.

What we collect from shoppers

Only what the widget needs to do its job:

We do not use any of this to build profiles across different merchants' stores. A shopper's identifier on one store has no connection to their identifier on another.

Consent

Each merchant chooses how consent is handled on their store. Where they select "Ask first", nothing is stored in the browser and no behaviour is recorded until the shopper accepts. Decisions are recorded so the merchant can evidence them.

How long we keep it

Who else sees it

We do not sell data and we do not share it with advertisers. It is processed by:

Where it is processed

Our servers are in [REGION]. If you are in the EU or UK, that may mean your data is transferred outside your region; we rely on [TRANSFER MECHANISM, e.g. Standard Contractual Clauses].

Your rights

If you are in the EU, UK, or a jurisdiction with comparable law, you can ask for access to your data, correction, deletion, a portable copy, or that we stop processing it. Shoppers should contact the store they visited; merchants can contact us at [EMAIL]. We respond within 30 days.

Security

Credentials merchants enter are encrypted before storage. Access to production data is limited to people who need it. We have not yet completed a formal security certification, and we would rather say so than imply one.

Contact

[EMAIL] · [POSTAL ADDRESS]
[IF APPLICABLE: EU or UK representative under Article 27]