Privacy Policy

Who decides about the customers' and consumers' information

The merchant decides which forms to publish, what they ask and who receives them, and keeps their complaints book because Peruvian law requires it to keep the book, answer each sheet and keep the sheets. For the information customers and consumers send, the merchant is responsible for it (the data controller) and we process it on the merchant's behalf, only to provide the app. Whoever wants to know how a store uses their information, or to exercise their rights over it, should ask that store; in the book, at the email shown on it.

Information we keep about the store

• Your store's domain (for example, your-store.myshopify.com) and an access token issued by Shopify, kept encrypted. The app asks for these permissions: to add and delete files in your store's Files, where it keeps your customers' photos and videos; to use the app proxy, which Shopify requires to show the forms, the book's page and the DNI y RUC lookup on your store's domain; to create checkout validations, so DNI y RUC can require the document at checkout; and to read and edit orders, so DNI y RUC can show you the latest orders with a document and add the document to an order when the customer gives it on the thank-you page. It doesn't ask for permissions over products or customers. It reads your store's name, to sign the emails, its primary domain, for the texts of its policies, and your app subscription.
• Your forms: their titles, fields, messages, case numbering and the email addresses of the people who receive them.
• Your complaints book: business name, RUC, address and book code, which appear on every sheet; the emails of who receives the sheets and of who answers personal data requests, the sender name, the sheets' numbering and whether the book's notice and its text in your privacy policy are visible on your store (the app reads your store's public home page and privacy policy to check).
• Your settings: where and for how long customers' files are kept, the sender name of the emails and the reminder of cases left waiting.
• DNI y RUC: whether it's on, which documents your boletas take, and how many document lookups the store made each month, to apply your plan's limit.

Where the forms' photos and videos are kept

The merchant chooses it in the app's settings:

• In the store's Files on Shopify (the default). Each file is first received and checked on our server, then added to the store's Files (Content → Files) with a random name, never the customer's, and deleted from our server. Shopify serves these files from a public link that does not expire: it can't be guessed, but anyone who has it can open the file. The links in the emails expire after 30 days, but they lead to that Shopify link, which keeps working.
• On our server (private). The files stay on our server and are only opened through signed links that expire: one hour in the app and 30 days in the emails.

Information customers send through a form

The app keeps what each form asks for and the customer types, which may include:

• Name, email address and phone number.
• An identity document number (for example a Peruvian DNI, foreign resident card, RUC or passport), which the app checks for a valid format.
• An order number, descriptions and any other answer the form asks for.
• Photos and videos the customer attaches.
• The case number, the date, the language of the form and, for the merchant's team, the case's status and an internal note.
• The privacy text the customer accepted, as the form showed it then. Every form asks for it.

The app does not keep the customer's IP address with the case: it is used for a few minutes, in memory, to limit repeated uploads. Like any web server, our server's access logs record the IP address of each request; they are used only for security and to fix problems. The forms set no cookies and do not track the customer.

Information consumers register in the complaints book

What the consumer writes in the Hoja de Reclamación (complaint sheet):

• Name, identity document, address or email and, if given, phone number; for a minor, the name of their parent or representative and, if given, their contact details.
• The product or service, the amount claimed, the order number if given, the details and what they ask for.
• How they want the answer, and the date and time they filed the sheet.
• The store's answer.
• If the sheet was filed in the store's physical book, what the store copies from it, with its number.

Name, document, address or email and details are required: without them, the law considers the sheet not filed. The rest is optional. Filing a sheet doesn't ask to accept this policy: the data is processed because the law requires the store to keep the book.

The book's page uses no tracking or analytics cookies.

Information customers give for their receipt (DNI y RUC)

When the store turns DNI y RUC on, the cart or the checkout asks the customer for the kind of receipt and their document: DNI, RUC and, if the store allows them, foreign resident card or passport. With a factura it also asks for the business name and fiscal address.

This information is saved in the order, in Shopify, as the order's attributes. We don't copy it to our database.

To check the document and fill in the factura, the number travels to our server, which looks it up in a copy of the reduced RUC register that SUNAT publishes as public information; we download it every day and don't send SUNAT anything. No other provider is asked today; if we start using one, we will say so in this policy first.

We keep a cache of the lookups for 30 days (one day when the document wasn't found) so as not to repeat them. It doesn't keep the document number, only an encrypted fingerprint of it, and it isn't linked to the customer, the order or the store. Of a RUC it keeps the business name, status, condition and fiscal address, which are SUNAT's public data; of a DNI, only the masked name (for example, “J*** P***”), which is all the customer sees. A RUC starting with 10 belongs to a person with a business and includes their DNI: like any RUC, it shows and keeps the full name and fiscal address SUNAT publishes, because they are the data the invoice carries. The cache is stored encrypted.

The customer's IP address is used at the moment, in memory, to limit how many lookups can be made and prevent abuse. It isn't kept.

How we use the information

Only to provide the app: show the forms and the book on the store; save each case and each sheet; number the sheets and work out their deadline; email each case to the people the merchant chose (and a confirmation to the customer, if the merchant turns it on); email each sheet's copy to the consumer and the store, the deadline reminders and the answer if the store sends it from the app; check the document a customer gives for their receipt and fill in the factura; produce the PDFs and exports the store asks for, also to hand them to Indecopi; show everything in the app and manage the subscription. We do not sell it, share it for advertising, or use it for any other purpose.

Who we share it with

• The store, which sees its own cases and every sheet of its book.
• Shopify, which hosts the store, the checkout and the orders, and passes the requests of the forms, of the book's page and of the document lookups to the app.
• Hostinger, our hosting provider, which operates the virtual private server in the United States where the app and its database are kept, and the attached files when the merchant chooses our server.
• MXroute, our email provider, in the United States, which delivers the emails of each case and each sheet. A case's files are not attached to the emails: they include links that expire after 30 days. A sheet's PDF copy is attached.
• Wasabi, our storage provider, in the United States, which keeps the server's backups (the database and the files on our server).

These providers process the data on our behalf and only to provide the app, which is why the data is transferred to the United States. We only entrust them with what is needed. Hostinger processes the data under a data processing agreement with standard contractual clauses; MXroute, under its terms of service, which exclude reading the emails or using them for other purposes; Wasabi, under its terms of service, which only store the backups.

Billing is handled entirely by Shopify. We never receive payment details.

How it is protected

Everything travels over HTTPS. The stores' access tokens, the book's consumer data and what they write, and the cases' document numbers, phones and internal notes are stored encrypted (AES-256), also in the backups. The cases and the sheets can be seen only from the app inside the store's Shopify admin. The pages on the store's domain come through Shopify's app proxy, which signs every request. The links the app gives to files and PDFs are signed and expire. No system is infallible: if we detect an incident that affects the book's data, we will tell the affected stores immediately and within 24 hours at the most.

How long we keep it

• DNI y RUC: the document lookups' cache, 30 days (one day when the document wasn't found). The documents saved in the orders stay in Shopify, under the store's control.
• Photos and videos in the store's Files: until the merchant deletes them, or for the time the merchant sets in the app (between 30 and 730 days), after which the app deletes them.
• Photos and videos on our server: 180 days by default, or the time the merchant chooses on the Pro plan (between 30 and 730 days). Then they are deleted and the case says so.
• Files uploaded to a form that was never sent: deleted within 24 hours.
• Cases: until the merchant deletes them, or until the store's data is erased after uninstalling the app.
• Complaint sheets: Peruvian law requires the store to keep them 2 years from when they are filed (DS 011-2011-PCM, art. 12), so the app doesn't let anyone delete them by hand. It deletes them on its own after 2 years and 3 months if they were answered, and after 5 years if they weren't, unless the store marked them as disputed. When Shopify asks to erase a customer's data, the app deletes their sheets older than 2 years that were answered and aren't disputed.
• When the app is uninstalled, Shopify notifies us 48 hours later. We then delete the access token, everything the forms keep for the store (forms, cases, files on our server and settings) and DNI y RUC's settings and monthly lookup counts. Files already in the store's Files stay there, under the merchant's control. The book's sheets are kept only to hand them back: we email the store a link to download its book, since its duty to keep the sheets goes on, and 28 days later we delete the sheets and the book's settings and send a proof of the erasure, with its date, the number of sheets and the downloads. If the store installs the app again before that, its book stays as it was.
• The database backups are kept 90 days: what is deleted also leaves them within that time.
• Of each book handed back we keep for 2 years a record with no consumer data: the store's emails, the number of sheets and the dates of sending, download and erasure.

For the store: details to register the book's data bank

As the owner of the data bank of your Libro de Reclamaciones, you must register it in Peru's Registro Nacional de Protección de Datos Personales and report the cross-border transfer to the United States (Regulation of Law 29733, arts. 21.2 and 42). These are the details the app provides for the form:

• Purpose: register the complaint sheets, send them to the consumer and the store, work out the deadline to answer and record the answer (Consumer Protection Code, art. 150, and DS 011-2011-PCM).
• Data: name, document type and number, address or email, phone if given, details of the parent or representative if the consumer is a minor, the product or service, the amount, the details, the request and the answer. No sensitive data is asked for; the consumer could include it in the sheet's details.
• Processor: Datios, the app's provider (hola@datios.com).
• Sub-processors and destination of the cross-border transfer: Hostinger (hosting and database), MXroute (sending emails) and Wasabi (backups), in the United States; and Shopify, the store's platform.
• Retention: 2 years from each sheet's filing, and up to 2 years and 3 months once answered; up to 5 years while unanswered, and while disputed.
• Security measures: encryption in transit (HTTPS), consumer data and access token encrypted in the database and its backups, signed links that expire, requests signed by Shopify and backups kept 90 days.

If the Authority asks you for more details about Datios or its providers, write to us at hola@datios.com.

Your rights

Customers and consumers can ask the store to access, correct or delete their information. The merchant finds a customer's cases in the app by email address and can delete them; a consumer's sheets are found by email or document and can be downloaded, but not deleted while the law requires keeping them. When a customer asks Shopify to erase their data, Shopify tells us and we automatically delete the cases sent with that customer's email address, with their files, and their sheets as described above. Cases sent with another email address, or without one, must be deleted by the merchant from the app. DNI y RUC keeps nothing linked to a customer: their document is in the store's orders, in Shopify. Merchants can write to us at hola@datios.com to exercise their own rights or with any question about this policy.

Changes to this policy

If we change what the app does with the information, we will update this page and its date, and email the stores at least 15 days before. Write to us at hola@datios.com.