Privacy Policy

1. Data Controller

PiqloLabs ("Piqlo", "we", "us"), a sole proprietorship (eenmanszaak) based in Amsterdam, the Netherlands, operates the piqlo.co platform. We are the data controller for the personal data of our account holders (the businesses and individuals who sign up) under the EU General Data Protection Regulation (GDPR). This policy describes that processing.

Some Piqlo features let a business collect personal data about its own customers through the Service. For that data, the business is the controller and Piqlo is a processor. We explain this in section 2.

For privacy inquiries, contact our privacy contact at privacy@piqlo.co.

We have not appointed a Data Protection Officer, as we are not required to under Article 37 GDPR. As PiqloLabs is established in the EU, no Article 27 representative is required.

2. When Piqlo is a Processor: Data You Collect Through Piqlo

If you use Piqlo as a business, some features let you collect personal data about your own customers through the Service. This includes:

• Loyalty members: when someone joins one of your stamp cards, we store on your behalf their first name, their email if they provide one, their stamp and reward history, and any marketing-consent choice they made at sign-up (whether they opted in, when, how, and for what).
• Saved contacts: when a visitor saves their details from your review or contact card, we store on your behalf the name, email, and phone number they submit, along with any consent choices.
• Customer notes and records: any notes you write about a customer or loyalty member, and any customer you add manually (the name, email, and phone you enter yourself).
• Wallet passes: to deliver and automatically update Apple Wallet and Google Wallet loyalty passes, we store device registration identifiers. See Apple Wallet and Google Wallet on our sub-processors page.

For this end-customer data, you are the data controller and Piqlo acts as your processor under Article 28 GDPR. We process it only to provide the loyalty and contact features to you, on your instructions, and never for our own marketing or other purposes. This relationship is governed by a Data Processing Agreement (verwerkersovereenkomst) that forms part of your agreement with us when you use these features. You can read it at our Data Processing Agreement page.

Requests from your customers.Because you are the controller of your customers' data, a request from one of your customers to access, correct, or delete their data is directed to you, the business. Piqlo helps you act on it: from your dashboard you can export your customer and loyalty records, and delete an individual customer, which removes their loyalty memberships, stamps, rewards, notes, saved contacts, and wallet registrations. We will also act on documented requests you send us as the controller. Piqlo does not operate a self-service portal for your customers; if one of your customers contacts us directly, we will forward their request to you, the business, so you can act on it as the controller.

3. Data We Collect

Account data: Email address, display name, profile picture, and email-verification status provided via your authentication provider (Google or email).

Payment data: We do not store credit card numbers. Payment processing is handled by Stripe, which acts as an independent data controller. We store only your Stripe customer ID and subscription plan.

QR code data: Destination URLs, titles, styling preferences, uploaded logos, AI style choices and prompts, and generated QR images that you create through the Service.

Scan analytics: When someone scans a QR code, we record: country, city, device type, operating system, and browser. We do not store raw IP addresses. An anonymized, irreversible salted fingerprint is used solely to de-duplicate repeat scans within a 24-hour window. It is kept for at most 24 hours and cannot be reversed to identify individuals.

Usage data: We measure traffic with Cloudflare Web Analytics, which is cookieless and does not set any tracking identifiers. We also record a small number of named events (such as Signup CTA clicked, Pricing viewed) to a first-party events store hosted on Cloudflare Analytics Engine. Event properties are flat strings or numbers and we do not record IP addresses or any third-party identifiers.

4. Legal Basis for Processing

We process your personal data under the following GDPR Article 6(1) bases:

• Contract performance (Art. 6(1)(b)): Account data, QR code data, and payment data are necessary to provide the Service you signed up for.
• Legitimate interest (Art. 6(1)(f)): Scan analytics (aggregated, no raw IPs) enable the core value of the Service: showing you how your QR codes perform.
• Legitimate interest (Art. 6(1)(f)): Aggregate site traffic measurement and named conversion events are processed using cookieless, first-party tooling that does not identify individual visitors.

Where we rely on legitimate interests, you have the right to object to that processing on grounds relating to your particular situation; contact privacy@piqlo.co. We have weighed these interests against your rights and consider the processing limited and non-intrusive (aggregate, cookieless, no raw IPs).

For personal data you collect about your own customers (section 2), the legal basis is yours to determine as the controller. Piqlo processes it on your instructions under our Data Processing Agreement.

5. How We Use Your Data

We use your data to provide and improve the Piqlo service: creating and managing QR codes, generating optional AI or animated QR artwork, displaying scan analytics, processing payments, providing support, and sending transactional emails such as account, billing, and service messages. We do not sell, rent, or share your personal data with third parties for marketing purposes.

6. Sub-Processors

We use a small set of trusted providers to operate the Service. Where a provider processes personal data for us, we rely on that provider's data processing terms and transfer safeguards, including Standard Contractual Clauses where required.

The full, current list of sub-processors, what each one does, and where data sits is on our sub-processors page. We keep it versioned, and we update it there whenever a sub-processor changes. Material additions are communicated as described in section 12 (Changes to This Policy).

7. Data Storage & Security

Piqlo runs entirely on Cloudflare. Your account data and the customer data you collect through Piqlo live in Cloudflare D1, which we created under Cloudflare's EU jurisdiction: a binding commitment that the database runs and stores its data inside the European Union, not a best-effort region hint. The Durable Objects that coordinate loyalty actions and account limits are pinned to the same EU jurisdiction. Card images live in Cloudflare R2 in Cloudflare's EU region (Western Europe). Most images are business design assets; where a wallet pass image reflects a member's stamp progress it carries no contact details, only a count. We also use Cloudflare KV, a cache that Cloudflare replicates globally for speed; we keep personal data in KV to a minimum, and any personal data that passes through it is covered by Standard Contractual Clauses. Cloudflare Inc. is a US-incorporated company, so we do not claim a transfer to the US can never occur; any limited transfer is covered by Standard Contractual Clauses. Data is encrypted in transit (TLS 1.2+) and at rest.

We employ security measures including per-account rate limiting, encrypted communications, validation that blocks redirects to private or internal addresses, constant-time comparison of secrets, ownership checks on every request, and fail-closed handling of loyalty actions. We review security as part of significant changes to the Service.

8. Data Retention

• Scan/tap event data: Individual events (country, city, device, but never a raw IP) are held in Cloudflare Analytics Engine for roughly 90 days, after which they age out automatically. Durable per-card totals are kept in your account and deleted when you delete your account or the card.
• Account data: Retained until you delete your account.
• QR images: Retained until you delete the QR code or your account. This includes generated AI QR artwork.
• AI prompts and style choices: Stored with the card while the AI artwork exists so the card can be displayed, supported, and regenerated if needed. Deleted when you delete the card or your account.
• Animated QR tool: Our free animated-QR tool renders in real time and streams the result back to you. We do not store the generated GIF or the source you picked.
• Customer data you collect (section 2): Loyalty members, saved contacts, and related records are retained while your account and the relevant card exist, and deleted when you delete the customer, the card, or your account, or when a loyalty program has been inactive for an extended period (currently 30 days after it is stopped), after which it is automatically removed.
• Payment records: Stripe retains payment data per their own retention policy and legal obligations.

9. Your Rights (GDPR)

Under GDPR, you have the right to:

• Access & portability:Export all your data in machine-readable JSON format via Settings > Export Data.
• Erasure (right to be forgotten):Delete your account and all associated data (cards, images, usage records) via Settings > Delete Account. Deleting your account also removes the customer and loyalty data you collected through Piqlo (see section 2). Deletion is immediate and irreversible from your live account; residual copies in routine backups or transient caches age out on their normal cycle. Aggregated scan statistics in our time-series store contain no direct identifiers and age out automatically within ~90 days.
• Rectification: Update your name and profile information at any time in Settings.
• Site analytics: We do not run third-party behavioural tracking, so there is no consent to withdraw. Our analytics are cookieless and aggregate by design.
• Object & restrict: Contact us at privacy@piqlo.co to object to processing or request restriction.
• Withdraw consent: Where we rely on your consent for any processing, you can withdraw it at any time by contacting privacy@piqlo.co, without affecting processing already carried out.
• Lodge a complaint: You have the right to lodge a complaint with your local data protection authority. In the Netherlands this is the Autoriteit Persoonsgegevens.

If you are an end-customer of a business that uses Piqlo (for example a loyalty member or someone who saved their contact details), the business is the controller of your data. Please direct access, correction, and deletion requests to that business; see section 2.

10. Cookies

Piqlo uses only strictly necessary cookies: authentication session management, and, if you build a card on our landing page before signing up, a temporary identifier cookie (piqlo_anon, 30 days) whose only purpose is to attach that card to your account when you sign up. We do not use advertising cookies, tracking pixels, or third-party analytics cookies. Site traffic and conversion events are measured with cookieless, first-party tooling and never set any tracking identifier on your device.

11. Children's Privacy

Piqlo is not intended for users under 16 years of age. We do not knowingly collect data from children. If you believe a child under 16 has provided us with personal data, contact us at privacy@piqlo.co and we will delete it promptly.

12. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes, including material additions to our sub-processors, will be communicated via email or an in-app notice. Continued use of the Service after changes constitutes acceptance of the updated policy.

13. Contact

For privacy inquiries, data requests, or complaints, contact our privacy contact:

Email: privacy@piqlo.co

For product support write to support@piqlo.co; for everything else, info@piqlo.co.

PiqloLabs, a sole proprietorship (eenmanszaak) · Amsterdam, the Netherlands