Privacy Policy

1.1 INTRODUCTION

Important information and who we are

At Zenbundle Limited (“we”, “us”, or “our”) we are committed to protecting and respecting your privacy and Personal Data in compliance with the General Data Protection Regulation (“GDPR”) laws.

This Privacy Policy explains how we collect, process and keep your data safe. The Privacy Policy will tell you about your privacy rights, how the law protects you, and inform our employees and staff members of all their obligations and protocols when processing data.

What this policy covers

This policy covers all Zenbundle products: our retail media and commerce media platform, our analytics and integrations, and our Shopify applications including Zenbundle AI Chat. Sections 1 to 4 apply to everyone. The sections dealing with shopper data, AI Chat and cookies apply where a merchant has installed one of our storefront applications. The sections referring to Google user data apply where a merchant has connected a Google account to our platform.

The individuals from which we may gather and use data can include:

• Customers
• Merchants who install our applications, and the shoppers who use those applications on a merchant’s storefront
• Suppliers
• Business contacts
• Third parties connected to your customers
• and any other people that the organisation has a relationship with or may need to contact.

This Privacy Policy applies to all our employees and staff members and all Personal Data processed at any time by us.

1.2 Your Data Controller

Zenbundle Limited is your Data Controller and responsible for your Personal Data. We are not obliged by the GDPR to appoint a data protection officer and have not voluntarily appointed one at this time. Therefore, any inquiries about your data should either be sent to us by email to support@zenbundle.com or by post to 5 Harcourt Road, Ireland D02 FW64.

You have the right to make a complaint at any time to the Data Protection Commission, the Republic of Ireland supervisory authority for data protection issues (www.dataprotection.ie). We would, however, appreciate the chance to deal with your concerns before you approach the Data Protection Commission, so please contact us in the first instance.

1.2a Our two roles

We act in two distinct roles depending on whose data is involved.

Where you are a merchant using our Platform or our Shopify applications, Zenbundle Limited is the Data Controller for your account, billing, support and usage data, as described in this policy.

Where a shopper interacts with a Zenbundle application installed on a merchant’s storefront, including Zenbundle AI Chat, the merchant is the Data Controller and Zenbundle Limited acts as a Data Processor on that merchant’s documented instructions, under the data protection terms in our Terms of Service. Shoppers wishing to exercise their rights in respect of that data should contact the merchant whose store they used. Where we can identify that merchant, we will forward the request to them and assist them in responding.

1.3 Processing data on behalf of a Controller and processors’ responsibility to you

In discharging our responsibilities as a Data Controller we have employees who will deal with your data on our behalf (known as “Processors”).

The responsibilities below may be assigned to an individual or may be taken to apply to the organisation as a whole. The Data Controller and our Processors have the following responsibilities:

• Ensure that all processing of Personal Data is governed by one of the legal bases laid out in the GDPR (see 2.2 below for more information);
• Ensure that Processors authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;
• Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the processing of Personal Data;
• Obtain the prior specific or general authorisation of the Controller before engaging another Processor;
• Assist the Controller in the fulfilment of the Controller’s obligation to respond to requests for exercising the data subject’s rights;
• Make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in the GDPR and allow for and contribute to audits, including inspections, conducted by the Controller or another auditor mandated by the Controller;
• Maintain a record of all categories of processing activities carried out on behalf of a Controller;
• Cooperate, on request, with the supervisory authority in the performance of its tasks;
• Ensure that any person acting under the authority of the Processor who has access to Personal Data does not process Personal Data except on instructions from the Controller; and
• Notify the Controller without undue delay after becoming aware of a Personal Data Breach.

2. LEGAL BASIS FOR DATA COLLECTION

2.1 Types of data / Privacy policy scope

“Personal Data” means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of Personal Data which we have grouped together below. Not all of the following types of data will necessarily be collected from you, but this is the full scope of data that we collect and when we collect it.

Profile/Identity Data: This is data relating to your first name, last name, gender, date of birth.

Contact Data: This is data relating to your phone number, addresses and email addresses.

Marketing and Communications Data: This is your preferences in receiving marketing information and other information from us.

Access Data: This type of service allows the Zenbundle Application to access Data from your account on a third-party service such as Google Analytics to analyze web traffic and user behaviour. Zenbundle’s use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

Billing Data: This is information relating to your debit and credit card information such as the name attached to your payment details and your billing address.

Financial Data: These are your banking details, for example your account number and sort code.

Transactional Data: This is information of details and records of all payments you have made for our services or products.

Shopper Data: Where a merchant installs a Zenbundle application on its storefront, we process data about that merchant’s shoppers on the merchant’s behalf. Depending on the features the merchant enables, this may include name, email address, telephone number, delivery and billing address, order history and order status, approximate location derived from IP address, IP address, browser and operating system, pages and products viewed, and a client identifier stored in the shopper’s browser.

Conversation Data: Where a merchant enables Zenbundle AI Chat, we process the messages a shopper types into the chat window, the responses generated, the products and pages shown, and technical metadata about the exchange such as timestamps, the store, a session identifier and processing cost. We retain these conversations so that the merchant can review them, so that we can measure and improve answer quality, and to detect abuse.

Special Categories of Personal Data

We do not ask for, and do not knowingly seek, Special Categories of Personal Data. This includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data. Nor do we ask for information about criminal convictions and offences.

Where a merchant enables a free-text feature such as AI Chat, a shopper may choose to include such information in a message. We do not solicit it, we do not use it to target, profile or advertise to that shopper, and we do not use it to train models. Merchants are responsible for configuring the topics their assistant will and will not discuss, and we provide controls for this.

2.2 The Legal Basis for Collecting That Data

There are a number of justifiable reasons under the GDPR that allow collection and processing of Personal Data. The main avenues we rely on are:

“Consent”: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or opt in to a service.

“Contractual Obligations”: We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.

“Legal Compliance”: We are required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.

“Legitimate Interest”: We might need to collect certain information from you to be able to meet our legitimate interests. This covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. Examples could be your address, so that we know where to deliver something to, or your name, so that we have a record of who to contact moving forwards.

Where we act as a Data Processor for a merchant, as described in section 1.2a, that merchant relies on its own lawful basis for the processing and we act on its documented instructions.

3. HOW WE USE YOUR PERSONAL DATA

3.1 Our data uses

We will only use your Personal Data when the law allows us to and strictly within the scope of providing or improving our services.

Set out below are the different types of Personal Data we collect and the lawful basis for processing that data. The purposes described below are indicative, and we ensure that all uses of your data are for related, functional purposes necessary to operate or enhance our services. We do not use your data for any purposes unrelated to the provision or improvement of our services.

For further inquiries please contact us.

Activity: User visiting the public website for the first time

Type of data: Technical Data, Usage Data.

Legal Justification: Legitimate Interest.

Lawful basis for processing data: We need to understand where you are logging in from so we know whether you can take advantage of our services, and what browser you are using so we can understand our customer demographic to help diagnose service provision issues, to keep our records up to date and analyse how customers use our services.

Activity: A User requesting and attending a live demo of our products or services, or inquiring into our services through a call with members of our sales or support team

Type of data: Profile / Identity Data, Contact Data.

Legal Justification: Consent.

Lawful basis for processing data: Certain company information will be taken at this time, including the name and position of the contact requesting the demo, further information or sales call.

Activity: User signing up to the platform and creating an account

Type of data: Profile / Identity Data, Contact Data, Transactional Data, Technical Data, Customer Support Data, Usage Data, Marketing and Communications Data.

Legal Justification: Consent, Contractual Obligations, Legitimate Interest.

Lawful basis for processing data: (a) Consent. You will need to include Personal Data when filling in the Company profile on the platform so the content you create is linked to your profile. (b) Contractual Obligation. In order to use our Platform you need to contract with us under our Terms of Service and so this data is necessary to form the contract between us. (c) Legitimate Interest. We need to understand where you are logging in from so we know whether you can take advantage of our services, and what browser you are using so we can understand our customer demographic to help diagnose service provision issues, to keep our records up to date and analyse how customers use our services.

Activity: User makes a purchase on the Website

Type of data: Profile / Identity Data, Financial Data, Contact Data, Transactional Data, Billing Data.

Legal Justification: Consent, Contractual Obligations, Legitimate Interest.

Lawful basis for processing data: (a) Consent. You will need to include Personal Data when filling in the Company profile on the Platform so the content you create is linked to your profile. We will retain the name that is stated on the credit or debit card you enter into our Stripe API, but all other card details are stored by them and not retained by us. (b) Contractual Obligation. In order to use our Platform you need to contract with us under our Terms of Service and so this is necessary to form the contract between us. We need to retain your Transactional Data so that we can comply with our legal obligation to send you an invoice following a purchase. (c) Legitimate Interest. We need to know who you are so that we know who to deliver the service to once it has been purchased. It also enables us to provide support to the right individual in case there is an issue with the purchased product.

Activity: User support with specific products

Type of data: Profile / Identity Data, Transactional Data, Customer Support Data, Usage Data.

Legal Justification: Consent, Contractual, Legitimate Interest.

Lawful basis for processing data: (a) Consent. We may need your telephone number or other further contact details if reaching out to you is best achieved via those details instead of our live chat. (b) Legitimate Interest. We will retain records of the transactions you have made with us and what you have used on the Platform so when you come to us with an issue we can quickly identify what your issue relates to and provide you with the most efficient support.

Activity: A shopper opens and uses the AI chat window on a merchant’s storefront

Type of data: Shopper Data, Conversation Data, Technical Data, Usage Data.

Legal Justification: Processed on behalf of the merchant, who relies on its own lawful basis, normally Legitimate Interest or Consent.

Lawful basis for processing data: We process the shopper’s messages in order to answer the shopper’s question using the merchant’s own product, stock, delivery and policy information, and to show the shopper relevant products. We do not use this data to build a profile of the shopper for our own purposes and we do not sell it.

Activity: A shopper asks the AI chat about an existing order

Type of data: Shopper Data including name, email address, delivery address, order contents and order status, and Transactional Data.

Legal Justification: Processed on behalf of the merchant, under the Contractual Obligation between the shopper and the merchant.

Lawful basis for processing data: Where a shopper supplies an order number together with the email address used to place that order, we retrieve that order from the merchant’s store in order to report its status and link the shopper to the merchant’s order status page. We do not return order information unless both details are supplied and match the order.

Activity: To administer and protect our business, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data

Type of data: Profile / Identity Data, Contact Data, Technical Data.

Legal Justification: Contractual Obligations, Legitimate Interest.

Lawful basis for processing data: (a) Legitimate Interest for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise. (b) Contractual Obligation to be able to comply with all legal obligations surrounding data collection, processing and retention.

Activity: To use data analytics to improve our website, products and services, marketing, customer relationships and experiences

Type of data: Profile / Identity Data, Transactional Data, Usage Data, Technical Data.

Legal Justification: Contractual Obligations, Legitimate Interest.

Lawful basis for processing data: Legitimate Interest, to define types of customers for our products and services, to keep our Site and Platform updated and relevant, to develop our business and to inform users about marketing strategy.

Activity: To use Google Analytics data to help with our retail media estimation and forecasting

Type of data: Profile / Identity Data, Transactional Data, Usage Data.

Legal Justification: Consent, Legitimate Interest, Contractual Obligations.

Lawful basis for processing data: Legitimate Interest. We need to know user and traffic performance data so that we can provide an estimate of the potential retail media revenue that your website could possibly generate.

3.2 Marketing and content updates

You will receive marketing and new content communications from us only if you have created an account and opted into receiving such communications. We may make suggestions and recommendations about products or services you may find useful. However, we do not use or share Google user data for marketing purposes unrelated to the core functionality of our services, and we do not market to shoppers who use our applications on a merchant’s storefront.

3.3 Change of purpose

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4. YOUR RIGHTS AND HOW YOU ARE PROTECTED BY US

4.1 Your legal rights

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

Right to be informed. You have a right to be informed about our purposes for processing your personal data, how long we store it for, and who it will be shared with. We have provided this information to you in this policy.

Right of access. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it, also known as a data subject access request. See section 4.4 below for more details on how you can make a data subject access request.

Right to rectification. You have a right to request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Right to erasure. You have the right to ask us to delete or remove personal data where there is no good reason for us continuing to process it, where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Right to object. You can object to the processing of personal data we hold about you. This effectively allows you to stop or prevent us from processing your personal data. Note that this is not an absolute right and it only applies in certain circumstances, for example where we are processing your personal data for direct marketing purposes, or where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may continue processing your data if we can demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Right to restrict processing. You have the right to request the restriction or suppression of your personal data. Note that this is not an absolute right and it only applies in certain circumstances: if you want us to establish the data’s accuracy; where our use of the data is unlawful but you do not want us to erase it; where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or where you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Right to data portability. You have the right to request the transfer of your personal data to you or to a third party. If you make such a request, we will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

If you wish to make a request under any of these rights, please contact us at support@zenbundle.com.

If you are a shopper

If you are a shopper who used a Zenbundle application on a merchant’s store, please direct your request to that merchant, who is the Data Controller for your data. If you contact us instead, we will forward your request to the relevant merchant where we can identify them, and assist that merchant in responding within the statutory time limits.

4.2 How Zenbundle Limited protects customers’ Personal Data

We are concerned with keeping your data secure and protecting it from inappropriate disclosure. We implement a variety of security measures to ensure the security of your Personal Data on our systems. Our admin web pages, along with our data processing systems, are protected with strong password credentials and accessible exclusively through Virtual Private Network (VPN) or Secure Shell Protocol (SSH). All data transmitted between systems or over networks and all data stored at rest are encrypted using industry-standard encryption protocols. Our data processing activities are hosted on Amazon Web Services (AWS), a secure and compliant cloud platform. AWS provides robust security features, including encryption for data in transit using protocols like TLS/SSL and data at rest using services like AWS Key Management Service.

Any Personal Data collected by us is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality. If and when we use subcontractors to store your data, we will not relinquish control of your Personal Data or expose it to security risks that would not have arisen had the data remained in our possession.

However, unfortunately no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of Zenbundle Limited to intercept or access transmissions or private communications unlawfully. While we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us.

4.3 Opting out of marketing promotions

You can ask us to stop sending you marketing messages at any time by emailing support@zenbundle.com.

Where you opt out of receiving these marketing messages, we will continue to retain other Personal Data provided to us as a result of interactions with us not related to your marketing preferences.

4.4 How to request your data and the process for obtaining it

You will not have to pay a fee to access your Personal Data, or to exercise any of the other rights. However, if your request is clearly unfounded, we could refuse to comply with your request.

We may need to request specific information from you to help us confirm your identity and ensure you have the right to access your Personal Data, or to exercise any of your other rights. This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

5. YOUR DATA AND THIRD PARTIES

5.1 Sharing your data with third parties

We may share non-Personal Data with third parties. We do not sell Google user data to third parties. Google user data may be shared only with subcontractors or affiliates who are subject to confidentiality obligations and solely to help us provide or improve our services. These third parties may use this data only in accordance with our instructions and exclusively for functional purposes.

We do not sell shopper data or the content of AI Chat conversations, and we do not share either with third parties for advertising purposes.

In the event of a change in control, acquisition, or transfer of our business, we may transfer Personal Data, including Google user data, only as necessary to maintain the app’s functionality. The acquiring entity will continue to follow this Privacy Policy or a comparable policy that upholds these standards.

We may share your Personal Data if legally required or to enforce our terms or this Privacy Policy. Any sharing of Google user data strictly complies with Google’s policies and is limited to essential, functional purposes.

5.2 Third-Party Links

Our Site may include links to third-party websites, plug-ins, or applications. Clicking on those links or enabling such connections may allow third parties to collect data. However, no Google user data will be shared with third-party websites unless essential for app functionality. We encourage you to review third-party privacy policies when you leave our Site.

5.3 Automated processing and AI models

Zenbundle AI Chat generates its replies using a large language model hosted by our cloud provider within our own cloud environment. Shopper messages and the merchant’s product, stock and policy information are sent to that model solely in order to generate a reply.

We do not use shopper messages, merchant catalogue data or generated replies to train, fine-tune or improve any third-party foundation model, and our model provider is contractually prohibited from doing so. We use conversation data only to operate the service, to report to the merchant, and to review and improve the quality of our own assistant.

Replies are generated automatically and are not reviewed by a person before they are shown. The assistant does not make decisions that produce legal effects concerning a shopper or similarly significantly affect them, within the meaning of Article 22 GDPR. Replies may be inaccurate or incomplete. The merchant’s own product pages, policies and customer service remain authoritative.

A current list of the sub-processors we use to deliver the Services is available on request by emailing support@zenbundle.com.

5.4 Cookies and similar technologies

On merchant storefronts, our applications store a client identifier in the shopper’s browser so that a conversation can be continued across page views and so that a merchant can measure how the feature performs. Where a merchant enables measurement, we also register a Shopify Web Pixel on that merchant’s storefront to record feature-related events.

We honour the Shopify Customer Privacy API and the merchant’s consent settings, and suppress tracking where consent has not been given. Shoppers can manage these preferences through the consent banner on the merchant’s store.

On our own website, we use cookies for essential site function and for analytics. You can manage these through the cookie settings link in our footer.

6. HOW LONG WE RETAIN YOUR DATA

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your Personal Data for a longer period than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

Conversation Data from AI Chat is retained for 12 months from the date of the conversation, after which it is deleted or irreversibly de-identified. Aggregated statistics that cannot identify a shopper, such as conversation counts, topics and answer quality scores, may be retained for longer.

Where a merchant’s agreement with us ends, we delete or return Client Data, including Conversation Data for that merchant’s store, within 30 days of termination or of the merchant’s written request, except where we are lawfully required to retain limited copies.

A merchant may request earlier deletion of a specific conversation, or of a specific shopper’s data, by contacting support@zenbundle.com.

7. AGE LIMIT FOR OUR USERS

You must be aged 18 or older to register for a Zenbundle account or to enter into an agreement with us for our Services. If you are under 18 and you have registered for an account, you must stop using it immediately.

Our applications on merchant storefronts, including AI Chat, are not directed at children. We do not knowingly collect Personal Data from children through them, and we do not ask a shopper’s age. Each merchant is responsible for its own audience and for any additional requirements that apply to selling to children in its market. If you believe a child has provided Personal Data through one of our applications, contact support@zenbundle.com and we will work with the merchant to delete it.

This website is not intended for children and we do not knowingly collect data relating to children.

8. INTERNATIONAL TRANSFER OF DATA

Our services are hosted on Amazon Web Services. Your information may be stored and processed in the European Economic Area, the United Kingdom, the United States or other countries where Zenbundle Limited or its sub-processors operate.

Where Personal Data is transferred outside the European Economic Area or the United Kingdom, we rely on a lawful transfer mechanism, including the European Commission’s Standard Contractual Clauses (Commission Implementing Decision (EU) 2021/914, Module 2) and, for the United Kingdom, the UK International Data Transfer Agreement or the UK Addendum. Where a recipient is certified under the EU-U.S. Data Privacy Framework, we may rely on the adequacy decision for transfers to that recipient.

Any transfer of Google user data is conducted in compliance with the Google API Services User Data Policy and strictly for providing or enhancing the app’s functionality. We adhere to industry-standard security practices to safeguard your data during these transfers.

9. NOTIFICATION OF CHANGES AND ACCEPTANCE OF POLICY

We keep our Privacy Policy under review and will place any updates here. This version is dated 10th September 2026 and replaces the version dated 4th November 2024. In this version we described how we process shopper data and chat conversations in our Shopify applications, set out our roles as controller and processor, described our use of AI models, added retention periods for conversation data, and added a section on cookies and similar technologies.

By using Zenbundle Limited, you consent to the collection and use of data by us as set out in this Privacy Policy. Continued access or use of Zenbundle Limited will constitute your express acceptance of any modifications to this Privacy Policy.

10. INTERPRETATION

All uses of the word “including” mean “including but not limited to” and the enumerated examples are not intended to in any way limit the term which they serve to illustrate. Any email addresses set out in this policy may be used solely for the purpose for which they are stated to be provided, and any unrelated correspondence will be ignored. Unless otherwise required by law, we reserve the right to not respond to emails, even if they relate to a legitimate subject matter for which we have provided an email address. You are more likely to get a reply if your request or question is polite, reasonable and there is no relatively obvious other way to deal with or answer your concern or question, for example FAQs or other areas of our website.

Our staff are not authorised to contract on behalf of Zenbundle Limited, waive rights or make representations, whether contractual or otherwise. If anything contained in an email from a Zenbundle Limited address contradicts anything in this policy, our terms or any official public announcement on our website, or is inconsistent with or amounts to a waiver of any Zenbundle Limited rights, the email content will be read down to grant precedence to the latter. The only exception to this is genuine correspondence expressed to be from the Zenbundle Limited legal department.

11. TERMS OF USE

Please also see our Terms of Service, which set out the terms, disclaimers, and limitations of liability governing your use of Zenbundle Limited.

General Compliance Statement

Zenbundle Limited is committed to protecting your privacy and strictly adhering to all relevant privacy policies and regulations. We do not sell Google user data, nor do we use or share it with third parties for any purposes other than those directly necessary for the app’s core functionality. Any use or transfer of Google user data complies with the Google API Services User Data Policy, ensuring that your data is used securely and responsibly.