Privacy Policy — UK Subscription Guard

Controller: MINISAGE TECH LTD (company no. 17229324)
Registered office: 18 Crowthorp Road, Northampton, NN3 5DU
App: UK Subscription Guard
URL: https://dmccaguard.co.uk/privacy
Version: 1.1 · 26 May 2026
ICO registration: C1941625


1. Who we are

MINISAGE TECH LTD ("we", "us", "our") is the data controller for personal data we collect about merchants (Shopify store owners and their staff) who install our app, UK Subscription Guard (the "App").

When we access your Shopify store's public policy pages to provide the audit service, we do so via the Shopify API with your authorisation. We do not store your customers' personal data in version 1 of the App.


2. What personal data we collect

2.1 Merchant and staff data (we are controller)

When you install the App via Shopify OAuth, we receive and store:

Data Why
Shopify shop domain (*.myshopify.com) To identify your store across sessions
Shopify staff user ID, first name, last name, email address OAuth session management
App access token (encrypted) To read your shop's policy pages via Shopify API
Billing plan, billing status, App subscription ID To enforce plan limits and process billing
DPA acceptance timestamp and version To record your agreement under UK GDPR Art. 28
Report download count per day To apply free-plan daily export limits
Install date, uninstall date Compliance record-keeping

Lawful basis: Performance of a contract (providing the App and associated services).

2.2 Public policy page content (transient — not stored)

To provide the compliance audit, the App reads the text of your publicly visible Shopify policy pages (Privacy Policy, Terms of Service, Refund Policy, Subscription Policy) via the Shopify Admin GraphQL API. This text is processed in memory to generate your compliance score and checklist. We do not store the text of your policy pages on our servers.

2.3 What we do NOT collect in version 1

Future versions that add pre-renewal reminder emails will process customer email addresses on your behalf as processor (not controller). An updated DPA will be presented before those features are enabled.


3. How we use your data

We do not sell personal data. We do not use personal data for direct marketing without your consent.


4. Sub-processors

We use the following third-party services to operate the App:

Sub-processor Service Location
Neon Tech Inc. PostgreSQL database (encrypted at rest) EU (Frankfurt region preferred)
Render Services Inc. Application hosting US (Oregon)
Shopify Inc. Platform OAuth, API, billing Canada / global (Shopify acts as independent controller for platform data)

We require each sub-processor to process personal data only as necessary to provide their service and to maintain appropriate security measures. Full list: https://dmccaguard.co.uk/sub-processors

We will notify you at least 30 days before adding a new sub-processor that processes personal data, giving you the right to object on reasonable grounds.


5. Data retention

Data Retention period
Shopify session (access token, user details) While App is installed; deleted within 48 hours of uninstall
Shop record (billing, plan, DPA acceptance) While App is installed + 30 days after uninstall for legal record-keeping
Audit score data Not stored (computed on demand, discarded after request)
Support correspondence 3 years from last contact

On uninstall, we process Shopify's shop/redact webhook and delete all shop-keyed personal data from production systems within 48 hours, and from backups within 30 days where technically feasible.


6. Your rights

As a merchant (data subject), you have the right under UK GDPR to:

To exercise any right, contact us at privacy@dmccaguard.co.uk or the support address below. We will respond within one calendar month.

You have the right to lodge a complaint with the UK Information Commissioner's Office (ICO): https://ico.org.uk/make-a-complaint/


7. Security

We implement appropriate technical and organisational measures, including:

In the event of a personal data breach affecting your data, we will notify you within 72 hours of becoming aware.


8. International transfers

Our hosting provider (Render) operates in the United States. Transfers of personal data to the US are covered by Standard Contractual Clauses (SCCs) as incorporated into Render's data processing addendum.

Our database provider (Neon) is configured to use the EU (Frankfurt) region where technically available, to keep merchant data within the UK/EEA where possible.


9. Changes to this policy

We will post any updates to this page with a new version date. For material changes (new categories of data, new processing purposes), we will provide notice in the App or by email at least 30 days before the change takes effect.


10. Contact

Privacy enquiries: privacy@dmccaguard.co.uk
General support: support@dmccaguard.co.uk
MINISAGE TECH LTD
18 Crowthorp Road, Northampton, NN3 5DU
United Kingdom


v1.1 — 26 May 2026 — MINISAGE TECH LTD — Not legal advice. Solicitor review recommended before publication.