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Privacy policy

DRAFT v1, not yet reviewed by a lawyer. Not in force until a lawyer has approved it.

Last updated: [date]

This policy exists in Dutch and English. If the two differ, the Dutch text prevails.

This privacy policy covers codesaur’s plugins and apps, such as “VAT & Company Autofill”, the website plugins.codesaur.nl and support. It has three parts, because what codesaur receives from you depends on how you use the software:

  • Part A. Plugins you install yourself (Shopware, WooCommerce, Adobe Commerce/Magento, PrestaShop): codesaur receives no personal data.
  • Part B. Hosted apps (Shopify, Lightspeed): codesaur processes data as a processor for the shop.
  • Part C. This website and support: codesaur is the controller.
  • A plugin on your own server sends nothing to codesaur: no telemetry, no usage data.
  • With a hosted app, codesaur processes buyers’ data only on the shop’s instructions, under a data processing agreement, within the European Economic Area.
  • codesaur does not sell data and does not use it to train AI models.
  • No cookies on this website, no analytics, no external fonts or scripts.

codesaur is the sole proprietorship (eenmanszaak) of Hans de Jong, registered with the Dutch Chamber of Commerce under number 42167270, established at De Dintel 19, 5463 NR Veghel, the Netherlands. Privacy questions: [privacy@codesaur.nl, confirm]. codesaur has not appointed a data protection officer; it is not required to.

The plugins for Shopware, WooCommerce, Adobe Commerce (Magento) and PrestaShop run on your shop’s server. They send no data to codesaur: no telemetry, no usage statistics and no licence check, except Freemius for WooCommerce Plus (A3). For these plugins codesaur is therefore not a processor, and you do not need a data processing agreement with codesaur.

You decide which checks the plugin performs. The plugin then contacts these sources directly from your server:

Source What the plugin sends Run by
VIES VAT number and country European Commission
PDOK postcode and house number Kadaster (Netherlands)
BeST postcode, street and house number Belgian authorities (address register)
KVK API, only if you switch it on, with your own key KvK number or search term Dutch Chamber of Commerce

What the plugin stores in your shop’s database, such as a temporary cache of answers, a log with masked input and the result of a VAT check on the customer, is under your control. You inform your buyers about this in your own privacy policy. A list of the sources, with links to their terms and privacy policies, is at plugins.codesaur.nl/vat-company-autofill/external-services/.

The paid WooCommerce Plus add-on is sold through Freemius. Freemius handles payment, invoices, VAT and licence keys as the seller (merchant of record) and is itself the controller for that data [confirm role]. The add-on contacts Freemius to check your licence and deliver updates. In doing so, [your site address, the licence key and the add-on version, confirm] are sent to Freemius. Freemius usage tracking is switched off [confirm]. What Freemius does with your data is governed by Freemius’s privacy policy. codesaur receives from Freemius [the buyer’s name, e-mail address, country and licence details, confirm], to provide the licence and support (performance of the contract, Art. 6(1)(b) GDPR). codesaur keeps this data while the licence runs and for [period] after; data that belongs to an invoice for 7 years (Dutch tax retention duty).

  • For a shop’s buyers (anyone who enters a VAT number, KvK number or address at checkout): the shop is the controller. codesaur processes that data only on the shop’s instructions, as a processor. The arrangements are in the data processing agreement at plugins.codesaur.nl/legal/dpa/. If you are a buyer with a question or request about your data, please contact the shop first; codesaur helps the shop answer.
  • For merchants (anyone who signs in to the app’s dashboard): codesaur is the controller for the data in B3.

B2. What codesaur processes for shops (as processor)

Section titled “B2. What codesaur processes for shops (as processor)”
Data Why Kept
VAT number, KvK number, postcode, house number, street to check them in the public registers and fill in the form answers cached: VIES 24 hours; PDOK, BeST and KvK 7 days
Masked copy of the input and the result (no IP address) to show the shop why a check failed 1 to 180 days, set by the shop (default 30)
One-way code (keyed hash) of the IP address to stop abuse (rate limits) at most 1 day
Data that Shopify sends in a webhook, encrypted to carry out the shop’s or Shopify’s request until the request is done or the buyer is erased; the record 7 days
Database backups recovery after an outage 14 days

codesaur queries VIES (European Commission), PDOK (Kadaster), BeST (Belgian address register) and, if the shop switched it on, the KVK API with the shop’s own key. These registers receive the number or address being checked. They are not codesaur’s sub-processors; they act under their own terms.

B3. What codesaur processes for merchants (as controller)

Section titled “B3. What codesaur processes for merchants (as controller)”
Data Why Legal basis Kept
E-mail addresses allowed to sign in to send sign-in links performance of the contract (Art. 6(1)(b) GDPR) until removed in the dashboard or the shop deletes its data
Sign-in link and session (as hash only), language to keep you signed in safely performance of the contract; legitimate interest in security (Art. 6(1)(f) GDPR) sign-in link 15 minutes (link from the platform 5 minutes); session 2 hours idle, 12 hours at most
Shop data: domain, settings, plan, encrypted platform access token, encrypted KvK key to provide the app performance of the contract until the app is removed or “Delete all data” is used; the Shopify access token is deleted when the app is removed
Number of KvK requests per month to provide the app and show KvK costs performance of the contract 24 months
Server access log (IP address [shortened, confirm], sign-in tokens removed) security and troubleshooting legitimate interest (Art. 6(1)(f) GDPR) [period, confirm]

Payments run through Shopify or Lightspeed. codesaur receives no payment details, only which plan the shop has.

The dashboard sets only strictly necessary cookies: a session cookie and a cookie against cross-site request forgery. These need no consent (Art. 11.7a(3) Dutch Telecommunications Act). No tracking or advertising cookies.

codesaur uses the providers in the sub-processor list at plugins.codesaur.nl/legal/subprocessors/: hosting, e-mail delivery and backup storage. All data is processed within the European Economic Area. codesaur does not transfer data to countries outside it.

In the dashboard (“Your data”) the merchant can download all data, empty the log at once and delete all data. On Shopify, the app also handles Shopify’s privacy requests automatically.

plugins.codesaur.nl is a static website. It sets no cookies, uses no analytics and loads no fonts, scripts or other files from third parties.

Data Why Legal basis Kept
Web server access log: shortened IP address, time, page requested, status code, browser type [confirm fields] to deliver and secure the website and fix problems legitimate interest (Art. 6(1)(f) GDPR) at most 3 months (90 days)

The IP address is shortened before it is stored IPv4 to /16, IPv6 to /32. The logs are kept in codesaur’s own monitoring system (SigNoz, self-hosted) on a server in [EU location, confirm]. Nobody else has access.

If you e-mail support@codesaur.nl, codesaur processes your name, e-mail address, the content of your message and what you attach, such as the “Copy diagnostics” text (versions, settings and masked error messages, without keys).

  • Why: to answer your question and to improve the software based on reported errors.
  • Legal basis: performance of the contract (Art. 6(1)(b) GDPR); without a contract, legitimate interest (Art. 6(1)(f) GDPR).
  • Kept: as long as needed to help you, at most 2 years after the last message.
  • Recipients: [e-mail provider, confirm], as processor.

Please do not send your buyers’ personal data unless it is needed.

For Shopware, PrestaShop and the free WooCommerce plugin, support runs through the store’s ticket system or forum. That store processes what you write there under its own privacy policy. codesaur sees your message and your name in that system and uses them only to answer you.

You have the right to access, rectify, erase and restrict your data (Art. 15 to 18 GDPR), to data portability (Art. 20 GDPR) and to object to processing based on legitimate interest (Art. 21 GDPR). If the data is processed by codesaur for a shop (part B2), that shop handles your request. codesaur answers within one month. codesaur makes no decisions about you based solely on automated processing.

codesaur protects data with appropriate measures, such as encrypted connections (TLS), encrypted storage of API keys, masked logs, only hashes of sign-in tokens and short sessions. The measures for the hosted apps are in Annex 2 of the data processing agreement.

Questions or requests about your data: [privacy@codesaur.nl, confirm]. If you are not satisfied with the answer, you can lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens, autoriteitpersoonsgegevens.nl) or with the supervisory authority in your own country (Art. 77 GDPR).

If this privacy policy changes, the date at the top changes too. codesaur announces material changes for the hosted apps at least 30 days in advance in the dashboard.