Privacy Policy

Hatálybalépés: November 1, 2025

Privacy Policy

Margyn Analytics Platform

Effective Date: November 1, 2025
Last Updated: October 29, 2026

1. Data Controller Information

Company Name: Interactic Media Korlátolt Felelősségű Társaság (Limited Liability Company)
Short Name: Interactic Media Kft.
Headquarters: 1143 Budapest, Eleonóra u. 8. 4/3, Hungary
Company Registration Number: 01-09-388500
Tax Number: 10580242-2-42
EU Tax Number: HU10580242
Contact: support@margyn.io
Website: https://margyn.io

Data Protection Contact: Máté Schubert
Email: support@margyn.io

Note: Interactic Media Kft. is not required to appoint a Data Protection Officer (DPO) under GDPR Article 37, as it is not a public authority and does not carry out large-scale systematic monitoring. We provide assistance with data protection questions through the above contact details.

2. Legal Framework

This Privacy Policy is based on the following legislation:

  • Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation, GDPR)
  • Act CXII of 2011 on the Right to Informational Self-Determination and Freedom of Information (Hungary)
  • Act CVIII of 2001 on Electronic Commerce Services and Information Society Services (Hungary)
  • Act XLVIII of 2008 on the Basic Requirements and Certain Restrictions of Commercial Advertising Activities (Hungary)

Supervisory Authority:
National Authority for Data Protection and Freedom of Information (NAIH)
Address: 1055 Budapest, Falk Miksa utca 9-11., Hungary
Phone: +36 (1) 391-1400
Email: ugyfelszolgalat@naih.hu
Website: https://naih.hu

3. Data Controller Status

IMPORTANT: Interactic Media Kft. acts as a data processor through the Margyn Analytics platform.

This means:

  • You (the Customer company) are the data controller for end-users' (customers, employees) personal data
  • We (Interactic Media Kft.) only process this data according to your instructions
  • You remain the owner and responsible controller of the data

Data Processing Agreement: By using our Service, you agree to enter into a Data Processing Agreement with us in accordance with GDPR Article 28. The Data Processing Agreement (DPA) is automatically accepted upon acceptance of the Terms of Service. The full DPA text is available at: docs/legal/dpa-en.md

4. Platform User Data (B2B Users)

4.1. Data Categories Collected

Data collected during registration and account management:

  • Name (first name, last name)
  • Email address
  • Company name
  • User password (irreversibly encrypted)
  • Account creation date
  • Last login timestamp
  • Chosen language and timezone preferences

Additional profile data (optional):

  • Phone number
  • Job title
  • Profile picture
  • Last seen timestamp
  • Account status information

Consent data:

  • GDPR consent given status and timestamp
  • Marketing communications consent
  • Data processing consent

Data automatically logged during use:

  • IP address
  • Browser type and version
  • Operating system
  • Pages and features visited
  • Clicks and interactions
  • Session ID
  • Access timestamps

4.1.1. Session Tracking

Data stored during session tracking:

  • Session identifier - Maintaining login
  • IP address - Security, fraud prevention
  • Device information - Technical compatibility assurance
  • Browser type - Proper display
  • Operating system type - System requirements verification
  • Country - Regional analysis (not precise location)
  • Session timestamps - Activity tracking, security verification
  • Organization identifier - Access management

Legal basis: Legitimate interest (GDPR Article 6(1)(f)) - Security, fraud prevention, technical compatibility
Data retention: 12 months - for security and troubleshooting purposes

4.1.2. Invitations and Access Management

User invitation system:

  • Invitee email addresses (pre-registration)
  • Invitation tokens - Secure access
  • Inviter user ID (invited_by) - Audit trail
  • Invitation messages - Optional context
  • Expiration dates - Security measure

Beta access codes:

  • Beta access codes - Early access control
  • Usage tracking - Access management
  • Validity periods - Time-limited access

Legal basis: Legitimate interest (GDPR Article 6(1)(f)) - Access control, security
Data retention: 90 days after expiration

4.2. Legal Basis for Data Processing

Data Type Legal Basis (GDPR) Justification
Registration data Article 6(1)(b) - Contract performance Essential for service delivery
Usage statistics Article 6(1)(f) - Legitimate interest Service improvement and security
Marketing communications Article 6(1)(a) - Consent Only with explicit consent
Billing data Article 6(1)(c) - Legal obligation Hungarian Accounting Act (8-year retention)

4.3. Data Retention Periods

Data Type Retention Period Justification
Registration data 5 days after account deletion Recovery option
Billing data 8 years Accounting Act requirement
IP addresses (logging) 15 days Security incident investigation, fraud prevention
Usage logs 12 months Security incident investigation
Marketing consent Until consent withdrawal GDPR Article 7(3)
Session data 12 months Security and troubleshooting purposes
Invitation data 90 days after expiration Security purposes, access control
AI operation logs (Gemini, Claude) Indefinite Organizational analytics, cost tracking - deleted upon request or organization termination
Billing events (Stripe webhook) Indefinite Audit purposes, legal obligation (8 years for accounting data)
Sentry error data 90 days Sentry default data retention policy
PostHog analytics data 12 months Usage analysis, service improvement
Upstash cache data 15 minutes - 24 hours TTL depending on key type (transient storage)

5. Customer End-User Data (E-commerce Shoppers, Employees)

5.1. Data Processor Role

The following end-user data may be processed through our platform:

For e-commerce platforms:

  • Customer names
  • Email addresses and, depending on the connected platform, phone numbers
  • City, region/state and country and, depending on the connected platform, the shipping postcode
  • Order data (amount, products, date, payment method, coupon code)
  • Order-source data (UTM tags, referrer), where the platform records it
  • Customer identifier (anonymous hash)

For HR/personnel costs:

  • Employee names (optional)
  • Salary/cost data
  • Job title (optional)

IMPORTANT: We process this data only according to Customer instructions:

  • Data owner: Customer company
  • Data controller: Customer company
  • Data processor: Interactic Media Kft.

5.2. Data Processing Purposes

  • Generate analytical reports for the Customer
  • Calculate business metrics (revenue, profit, efficiency)
  • Trend analysis and forecasts
  • Display dashboards and charts

5.3. Data Processing Location

Server location: European Union (Frankfurt, Germany)
Provider: Supabase Inc. (EU infrastructure)

International data transfer: The database is stored in the EU (Frankfurt, Germany). Some parts of the service send data outside the EU, and only when that feature is used: AI features are processed temporarily on servers in the USA (section 6.4), some of the service providers named in this policy are based or run servers in the USA, and if you switch on the advertising integrations, Meta and Google may pass data on to the USA under Standard Contractual Clauses and the EU-US Data Privacy Framework (sections 6.5 and 6.6).

5.4. E-commerce Platform Integrations

The Service automatically retrieves and processes the following data from e-commerce platforms connected by the Customer (e.g., Shopify, UNAS, WooCommerce):

Shopify integration:

  • Order data (order number, amount, date, status)
  • Product information (name, price, cost price, inventory)
  • Customer data (name, email - only per Customer instruction)
  • Shipping information (methods, fees)

UNAS integration:

  • Order data (order number, amount, date, status)
  • Product information (name, price, inventory)
  • Customer data (name - only per Customer instruction)

WooCommerce integration:

  • Order data (order number, amount, date, status, payment method, refunds, coupon code)
  • Product information (name, price, inventory, cost of goods where the store records it)
  • Customer data (name, email address, phone number, city, region/state and country, the shipping postcode and the WooCommerce user ID - only per Customer instruction)
  • Shipping and payment methods
  • Order-source data (UTM tags, referrer and landing page), if WooCommerce saved them on the order

For WooCommerce orders, the Provider does not store the shopper's IP address, browser user agent, street address, order key or card data.

API access:
The Service reads data through the connected platforms' interfaces. For example, Shopify, Google Ads, Meta Ads, TikTok Ads and Klaviyo connect through OAuth 2.0 authorization, and UNAS, WooCommerce and ChatGPT Ads, among others, connect with an API key that the Customer creates in the platform; the Provider encrypts such API keys (AES-256-GCM) before storing them. A WooCommerce key is read-only by default; if the Customer turns on instant updates, a read/write key is used only for the Provider's own webhook in the store (adding, removing and re-activating it). When a WooCommerce store is disconnected, the Provider deletes the stored key and attempts to remove its webhook; the key itself stays in the Customer's store until the Customer revokes it there (WooCommerce > Settings > Advanced > REST API).

Data responsibility:
For end-user data from e-commerce platforms, the Customer is the data controller, the Provider is the data processor. Obtaining end-user consent is the Customer's responsibility.

6. Detailed Data Processing Flows

6.1. Subscription and Payment

Subscription process:

  1. Customer selects a subscription plan
  2. Provides billing information (company name, address, tax number)
  3. Provides payment information directly to Stripe (secure plugin)

Payment data processing:
The Provider does not store or see bank card data. Payment information is provided by the Customer directly to Stripe through an embedded, Stripe-operated payment form.

Stripe details:

  • Company: Stripe Payments Europe, Limited
  • Address: 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, D02 H210, Ireland
  • Registration Number: 533780
  • Website: https://stripe.com
  • Stripe Privacy Policy: https://stripe.com/privacy

Information received from Stripe:

  • Payment successful/failed status
  • Transaction identifier
  • Payment amount and currency
  • Last 4 digits of card (for verification)

More about Stripe's operations and data processing: https://stripe.com/privacy

Billing data:

  • Retention period: 8 years (Hungarian Accounting Act requirement)
  • Company name, address, tax number
  • Subscription type, fee, period
  • Invoice number, issue date

6.2. Customer Support and Assistance

Contact channels:

Data processed during customer support inquiries:

  • Name (from User profile)
  • Email address (for contact)
  • Subject and content of inquiry
  • Attached files (screenshots, logs)
  • IP address and timestamp (for security)

Purpose of processing: Contract performance (GDPR Article 6(1)(b))

Data retention:

  • During active case handling
  • Closed cases: 12 months (for claims, enforcement)
  • Automatic deletion thereafter

Third-party involvement:
We do not currently use external providers for customer support. All inquiries are handled by our internal team.

6.3. System Messages and Email Communications

The Service sends the following automatic system messages during use:

Transactional emails (mandatory, cannot unsubscribe):

  • Registration confirmation
  • Password reset link
  • Subscription activation/renewal
  • Invoice delivery
  • Account deletion confirmation

Notification emails (optional, can be disabled):

  • New feature announcements
  • Important Service updates
  • Security notifications

Email sending provider:

  • Company: Resend Labs, Inc.
  • Address: 440 N Barranca Ave #7938, Covina, CA 91789, USA
  • Website: https://resend.com
  • Data center: USA (AWS)
  • Data protection: GDPR-compliant, Standard Contractual Clauses (SCC)

Data transmitted to Resend:

  • Recipient email address
  • Recipient name (if provided)
  • Email subject and content
  • Attachments (if any)

Data retention at Resend:
Resend retains email delivery logs for 30 days, then automatically deletes them. Email content is not stored long-term.

6.4. AI Image Generation and Business Analysis

The Service uses artificial intelligence for image generation and business metrics analysis:

Google Gemini AI service:

AI functions used:

  • Image generation and analysis: Product image analysis and description, marketing text generation, image variation creation, creative suggestion recommendations
  • Business metrics analysis: Profit metrics explanation, trend interpretation, business insights generation

Data transmitted to AI:

  • Uploaded product images (for image generation feature)
  • User-written prompt texts
  • Selected style settings
  • Aggregated business metrics (statistics only, no personal data)

Anthropic Claude AI service:

AI functions used:

  • In-depth business metrics analysis
  • Outlook generation
  • Detailed explanations and recommendations

Data transmitted to AI:

  • Aggregated business metrics (revenue, profit, margins)
  • Cost components and campaign performance indicators
  • DOES NOT include customer personal data - only aggregated statistics

AI Operations Logging:
We log all AI requests and responses in detail with the following information:

  • Organization identifier
  • Operation type (business analysis, report generation, image generation)
  • AI provider used
  • Resources consumed (token count, cost)
  • Operation duration
  • Operation metadata - request and response content
  • Status and error messages
  • Timestamps

Data Retention (AI logs): Indefinite - for organizational analytics and cost tracking purposes. Deleted upon organization termination or upon request.

Important guarantees:

  • AI services are only used if the Customer explicitly activates the respective AI feature
  • Google and Anthropic do not store data sent via API to train models
  • Copyright for AI-generated content belongs to the Customer

Data flow:
Data sent to AI features is temporarily processed on US servers (Google and Anthropic), then the response returns to our EU servers. AI providers delete the data after processing.

Automated Decision-Making:
AI analyses provide recommendations and insights, but final business decisions are always made by you. We do not employ automated decision-making per GDPR Article 22.

Consent withdrawal:
The Customer can disable AI features at any time in Settings, preventing any future data transmission to AI providers.

6.5. Profit Attribution (Meta Conversions API)

This feature is optional and disabled by default. It becomes active only if an Administrator enables it for the account and the Customer records a marketing-consent attestation in the platform Settings. Both are required — if either is missing, nothing is sent.

Availability: This feature is available for stores connected through UNAS and, where the Provider has enabled it for the store, Shopify. Orders from WooCommerce stores are never sent to Meta.

When active, after each order placed with the shopper's marketing consent, the Provider transmits the order's net profit (contribution margin) together with matching identifiers (most of them hashed — irreversible, SHA-256) to the Customer's own Meta dataset, as a separate custom event named margyn_profit. This lets Meta match the order to the right person and optimise the Customer's advertising toward profit rather than revenue alone.

  • Recipient: Meta Platforms Ireland Ltd. (Ireland, EU), which may onward-transfer to Meta Platforms, Inc. (USA) under Standard Contractual Clauses and the EU-US Data Privacy Framework.
  • Data transmitted: the order's profit value, currency and order timestamp; the shopper's email address, phone number, first and last name, city, postcode, country and the store's customer ID, each hashed (SHA-256) before it leaves the Provider (pseudonymous identifiers — still personal data under the GDPR); Meta's own browser identifiers (_fbc/_fbp cookies) when present; and the shopper's IP address and browser user agent (the text that names the shopper's browser and device), sent unhashed with each event. Meta requires the browser user agent for website events and does not accept these two fields hashed. They are sent only for orders where the shopper accepted marketing cookies, and only when the Provider's checkout tracking script on the store recorded them at the time of purchase. The Provider keeps the IP address and user agent for at most 30 days, then deletes them.
  • Shopper consent: sent only for orders where the shopper accepted marketing cookies on the store, checked for each order.
  • Purpose: advertising measurement and optimisation, carried out on the Customer's behalf and instruction.
  • Legal basis: the Customer's (Data Controller's) documented instruction, relying on the end-customer's marketing consent. The Customer is responsible for ensuring its own store privacy policy discloses this sharing with Meta and that a valid lawful basis exists.
  • Separation from revenue: by default the profit is sent as the separate margyn_profit event, never as a Purchase event, so it does not overwrite, duplicate, or inflate the Customer's revenue or conversion data. If Meta's native profit optimisation is switched on for the store, the profit is instead added as the net_revenue field of the store's own Purchase event, with the same identifiers and the same per-order consent check; the purchase value itself is unchanged.

The Customer can withdraw consent at any time in the platform Settings, which immediately stops all further transmission.

6.6. Profit to Google Ads (Google Data Manager API)

This feature is optional and disabled by default. It becomes active only if an Administrator enables it for the account, the Customer authorizes it in the platform Settings, and the Customer grants Google's Data Manager permission to Margyn.

Availability: This feature is available only for stores connected through UNAS. Orders from WooCommerce stores are never sent to Google.

When active, for each order that followed a click on a Google ad and was placed with the shopper's marketing consent, the Provider sends the order's net profit (contribution margin) to a "Margyn profit" conversion in the Customer's own Google Ads account. If the Customer also turns on the optional revenue conversion, the Provider sends such orders' gross revenue (the order total) to a separate "Margyn revenue" conversion, with the same identifiers and consent signals.

  • Recipient: Google Ireland Limited (Ireland, EU), which may onward-transfer to Google LLC (USA) under Standard Contractual Clauses and the EU-US Data Privacy Framework.
  • Data transmitted: order ID, purchase time, currency, the order's profit value (and, only while the revenue conversion is on, its gross revenue), and the Google click identifier (gclid, gbraid or wbraid), with Google's consent signals set to "ad user data: granted" and "ad personalization: denied". No email address, phone number, name, address or IP address is sent.
  • Purpose: conversion measurement and, only if the Customer chooses it in Google Ads, bidding on profit.
  • Legal basis: the Customer's (Data Controller's) documented instruction, relying on the end-customer's marketing consent. The Customer is responsible for disclosing this sharing with Google in its own store privacy notice.

The Customer can stop it at any time in the platform Settings.

6.7. Storefront measurement: shopping funnel and Meta events (UNAS and Shopify stores)

On UNAS stores the Customer can switch on the Provider's attribution pixel in the platform Settings (premium add-on). For shoppers who accepted marketing cookies it reads the ad click identifiers (fbclid, gclid, gbraid, wbraid, ttclid) from the landing page's address, keeps the last ten in the first-party cookie _margyn_click (90 days), and links them to the order on the thank-you page.

6.7.1. Shopping-funnel measurement

This feature is optional and disabled by default. It becomes active only if the premium add-on is on for the account and the Customer, through a user with the owner or admin role, switches on the shopping-funnel measurement in the platform Settings after the attribution pixel is switched on there, confirming that the store's own privacy notice covers it; on Shopify stores the Provider switches it on at the Customer's request. It then runs through the Provider's storefront script (UNAS stores) or the Provider's Shopify app pixel (Shopify stores).

When active, it records how a visit moves through the store, so that the Customer can see at which step visits from each traffic source stop.

  • Data recorded for each visit: a random visit identifier (not linked to a name, e-mail address or customer account); the steps the visit reached (visit start, product view, add to cart, checkout start, order); an identifier of each recorded step (random on UNAS; on Shopify taken from Shopify's own identifier of the event); the time the Provider received each step; the product ID for the product view and add-to-cart steps; the visit's traffic source as a label (for example "paid social" or "direct"), worked out from the landing page's campaign parameters, the referring website's domain and whether the landing came from an ad click; the type of that ad click (Meta, Google or TikTok — never the click identifier itself); the landing page's campaign parameters (utm_*, dropped if they contain an e-mail address or look like a phone number); the type of the landing page (for example home, product or category page); and whether the visit is counted on marketing or on statistics consent. No IP address, browser user agent, page address, name or contact detail is stored with these records.
  • Cookie: _mgn_s, a first-party cookie on the store's own domain. It holds the visit identifier, the steps already recorded, the visit's traffic source, the ad-click type, the landing page's campaign parameters (utm_*) and the landing page's type, and expires after 30 minutes without activity.
  • Link to the order: when a visit ends in an order, the order's consent record (the one described in section 6.5) also stores the visit identifier, so the Customer sees the order value and contribution margin per visit. The link is kept only for orders placed with the shopper's marketing consent (or on a store in statistics mode, see below). It is deleted when the order's consent record shows a refusal of marketing cookies at checkout, and on Shopify also when the shopper withdraws marketing consent later in the same visit — the orders of that visit then also count as not consented.
  • Shopper consent: only visits of shoppers who accepted marketing cookies are measured. Nothing is stored or sent before the shopper decides. "Statistics mode" also counts shoppers who accepted only statistics cookies; it is off for every store unless the Provider switches it on for the account, those visits are shown separately and are never sent to any advertising platform. On Shopify the app pixel only runs for shoppers who accepted marketing cookies, so statistics mode adds no Shopify visits.
  • Retention: the records wait in a short-lived queue for normally a few minutes before they are written to the database. The per-visit records are deleted 90 to 97 days after the visit (a whole week is deleted at once). The daily totals made from them contain no visit identifier and are kept for 25 months.
  • Use: only inside the platform, for the Customer's own funnel reports. These records are not sent to Meta, Google or any other third party. The Meta events that may be built from the same visits are described in section 6.7.2.
  • Erasure: offboarding the store, and Shopify's shop-deletion request, delete all funnel records of the store. A shopper's erasure request (on Shopify: the customer-deletion request) deletes the visits linked to that shopper's orders.
  • Legal basis and responsibility: the Customer's (Data Controller's) documented instruction, relying on the consent the store collects in its cookie banner. The Customer is responsible for asking its shoppers for consent and for disclosing this measurement in its own store privacy notice.

6.7.2. Meta events sent by Margyn

This feature is optional and disabled by default. It becomes active only if the premium add-on and the shopping-funnel measurement (section 6.7.1) are on for the account, the Customer has authorized Profit to Meta Ads (section 6.5), the Customer confirms in the platform Settings that it switched off the store platform's own Meta pixel and Conversions API (on Shopify: the customer data sharing of Shopify's "Facebook & Instagram" app) and, on UNAS stores, that the store does not sell products whose purchase can reveal a shopper's health, sex life or sexual orientation, and the Provider's automated checks find no other Meta sender on the store during the 24 hours after that confirmation. On UNAS stores the feature then switches on automatically; on Shopify stores a member of the Provider's staff also approves it before it switches on. If the feature is stopped because the Customer's Meta dataset changed, another Meta sender was found or a required setting (such as the shopping-funnel measurement) was switched off, it runs again only after a new confirmation and a new 24-hour check; on Shopify, a changed dataset or another Meta sender also needs a new approval. A pause ordered by the Provider can only be lifted by the Provider.

When active on a UNAS store, the Provider's storefront script loads the Customer's Meta pixel only after the shopper accepts marketing cookies, and sends the store's Meta events (page view, product view, add to cart, checkout start, purchase) to the Customer's own Meta dataset both from the shopper's browser and from the Provider's servers, with a shared event ID so that Meta counts each event once. If the shopper withdraws consent, the pixel is told to stop at once and Meta's cookies (_fbp, _fbc) are deleted from the shopper's browser.

On a Shopify store Meta's browser pixel is not loaded at all: the Provider's Shopify app pixel (which runs in Shopify's isolated pixel sandbox) reports the same store events to the Provider, and the Provider sends them to the Customer's own Meta dataset from its servers only (Meta Conversions API), each with its own event ID. The app pixel runs only for shoppers who allowed marketing cookies in the store's cookie banner (Shopify's customer privacy settings), and it forwards nothing to Meta for any other shopper. When a shopper withdraws marketing consent, the app pixel stops at once and erases the Meta browser identifier it created; the Provider drops that shopper's events that are still waiting to be sent and treats the orders of that visit as not consented, so their purchase is not sent. On Shopify the Provider may set two first-party cookies on the store's domain for this: _mgn_s (the shopping funnel's visit cookie, section 6.7.1) and, when Meta's own _fbp browser identifier is missing, an _fbp value in Meta's format (90 days).

  • Recipient: Meta Platforms Ireland Ltd. (Ireland, EU), which may onward-transfer to Meta Platforms, Inc. (USA) under Standard Contractual Clauses and the EU-US Data Privacy Framework.
  • Data transmitted: the event name and time; the page address (the store's domain and path, with only campaign (utm_*) parameters kept); where relevant, the product ID and a value with its currency — on UNAS the value of the items added to the cart (price × quantity); on Shopify the viewed product's price, the value of the items added to the cart (price × quantity) and the checkout total; Meta's own browser identifiers (_fbp/_fbc); and the shopper's IP address and browser user agent in readable form, as Meta requires for website events. For a purchase: the order value (gross total, including VAT and shipping), currency and order ID, and the same hashed (SHA-256) identifiers as in section 6.5, only for orders with the shopper's marketing consent, checked for each order.
  • Storage by the Provider: for page, product, cart and checkout events, the IP address and user agent are held only in a short-lived queue until they are sent (normally minutes; the queue deletes them itself after at most one hour, even if they could not be sent) and are never stored in the Provider's databases. For a purchase, the Provider uses the IP address and user agent it already records with the order when the shopper's marketing consent is captured on the thank-you page (on Shopify: by the Provider's app pixel at checkout completion), and erases them after 30 days.
  • Shopper consent: nothing is loaded or sent for shoppers who did not accept marketing cookies.
  • Purpose, legal basis and responsibility: as in section 6.5. The Customer remains responsible for asking its shoppers for consent and for disclosing this sharing with Meta in its own store privacy notice.

The Customer can pause or switch off this feature at any time in the platform Settings; switching it off takes effect immediately.

6.8. TikTok pixel run by Margyn (UNAS stores)

This feature is optional and disabled by default. It becomes active only if the premium add-on and the shopping-funnel measurement (section 6.7.1) are on for the account, the Customer enters its TikTok pixel ID and TikTok Events API access token in the platform Settings and confirms that it removed every other TikTok pixel from the store (including the store platform's own TikTok pixel), the Provider's checks find no other TikTok pixel on the store, and a member of the Provider's staff approves the pixel. The approval is given for one pixel ID and is needed again after a new pixel ID is entered, after the Provider's checks find another TikTok pixel, and after the Provider's staff pauses the feature.

When active, the Provider's storefront script loads the Customer's TikTok pixel only after the shopper accepts marketing cookies, and sends the store's TikTok events (product view, add to cart, checkout start, purchase) to the Customer's own TikTok pixel both from the shopper's browser and from the Provider's servers (TikTok Events API), with a shared event ID so that TikTok counts each event once. Page views are sent from the shopper's browser only. By default the purchase is sent from the Provider's servers only; the shopper's browser also sends it only if a member of the Provider's staff switches this on after checking that the store's page reports the same gross order total. If the shopper withdraws consent, the pixel is told to stop at once, and TikTok's cookies (_ttp, ttclid, ttcsid, _tt_enable_cookie) and TikTok's entries in the browser's session storage are deleted from the shopper's browser.

  • Recipient: TikTok Technology Limited (Ireland, EU) and TikTok Information Technologies UK Limited (United Kingdom). TikTok's Jurisdiction Specific Terms for the European Economic Area (Part B) state that the Customer and TikTok are joint controllers (Article 26 GDPR) for collecting and sending this event data, and TikTok's Business Products (Data) Terms (section 6.2) state that TikTok keeps event data for up to 18 months (both as published at ads.tiktok.com, read on 28 September 2026).
  • Data transmitted: the event name and time (page views, product views, add to cart, checkout start and purchases); the page address (the store's domain and path, with only campaign (utm_*) parameters kept); the product ID, quantity, price, cart value and currency where relevant; TikTok's own browser identifiers (the _ttp cookie and the ttclid click ID); and the shopper's IP address and browser user agent in readable form, as TikTok matches them. For a purchase: the order value (gross total, including VAT and shipping), currency and order ID; the shopper's email address, phone number and the store's customer ID, each hashed (SHA-256) before it leaves the Provider; the click ID recorded at checkout; and the IP address and user agent — only for orders placed with the shopper's marketing consent, checked for each order. Once loaded, TikTok's own script may collect further data according to the pixel's settings in TikTok Events Manager, which the Customer controls; the Provider asks the Customer to switch off Automatic Advanced Matching there.
  • Storage by the Provider: the Customer's Events API access token is stored encrypted, is never shown again, and is deleted when the Customer switches the feature off. For product, cart and checkout events, the IP address and user agent are held only in a short-lived queue until they are sent (normally minutes, at most one hour) and are never stored in the Provider's databases. For a purchase, the Provider uses the IP address and user agent it already records with the order when the shopper's marketing consent is captured on the thank-you page, and erases them after 30 days.
  • Shopper consent: nothing is loaded or sent for shoppers who did not accept marketing cookies, including shoppers who allowed statistics cookies only.
  • Transfers outside the EEA: TikTok's own terms and privacy policy govern what TikTok does with the data it receives. On 2 May 2025 the Irish Data Protection Commission announced a €530 million fine on TikTok Technology Limited over transfers of EEA users' personal data to China, with an order to suspend those transfers unless brought into compliance within six months. TikTok appealed; in November 2025 the Irish High Court put the order on hold, under conditions, while the appeal runs, and on 23 December 2025 the Irish Supreme Court granted the Commission leave to appeal against that decision (as reported in the Commission's 2025 annual report, published in June 2026). The Commission opened a second inquiry into TikTok's transfers in July 2025. The Customer should weigh this in its own assessment before switching the feature on.
  • Purpose, legal basis and responsibility: advertising measurement and optimisation, on the Customer's (Data Controller's) documented instruction, relying on the shopper's marketing consent. The Customer remains responsible for asking its shoppers for consent (its cookie banner must name TikTok under marketing cookies) and for disclosing this sharing with TikTok in its own store privacy notice.

The Customer can pause or switch off this feature at any time in the platform Settings. The Provider's servers stop sending at once. The storefront script is updated at once as well; if the store platform cannot be reached at that moment, the update follows within about 30 minutes, and until then the script still loads TikTok only for shoppers who accepted marketing cookies.

6.9. Free Tracking Audit (margyn.io)

The free tracking audit on margyn.io is open to anyone, without an account.

What we check: only the public web address you enter. We read the store's public homepage, then visit the store with an automated browser the way a shopper would: before any cookie choice, after rejecting and after accepting cookies, one product page, the cart and the first page of checkout. We never type into a form, never submit personal data and never place an order. We record which tracking tools fired and when; we do not keep the store's page content. The homepage address is also sent to Google PageSpeed Insights (Google Ireland Limited) to measure loading speed.

Public reports: the result of each completed check is published at margyn.io/{language}/audit/{store address} and in a machine-readable form (margyn.io/api/v1/public-audits/{store address}), with the date and the store's earlier checks. A public report shows the score, which steps our browser could complete, the Google PageSpeed scores, and each finding's title, severity and points (a title can name a tracking tool, for example "Meta pixel fired before any cookie choice"). To build these reports we keep the technical result of the check: which steps our browser completed (with the addresses of the pages it opened and the labels of the buttons it clicked), which tracking tools fired at each step, the public account IDs they sent, and the names and lifetimes of the cookies they set (never cookie contents). Any visitor's browser can see these on the store's public pages. Neither the report nor the stored result contains anything about the person who ran the check.

  • Legal basis: our legitimate interest in publishing the results of our free tool, and the public's interest in knowing how online stores track their visitors (GDPR Article 6(1)(f)). Where a store's address or a published account ID identifies a person (for example a sole trader), that person can object at any time (Article 21) by writing to support@margyn.io. We then delete the store's reports and do not publish new checks of it; we keep only the store address and the date of the request, so that we can honour it.
  • Removal: the store's owner can ask us to take the reports down by writing to support@margyn.io. Write from an address on the store's domain or the one in the store's legal notice; from any other address we may ask you to show that the store is yours. Within 3 working days we delete the store's reports, which removes them from the report page, the machine-readable form and our sitemap.

Your email address (only if you ask for the full report): we email you a 6-digit code to confirm the address, then send the report to it.

  • Data: email address, the store address checked, language, date and time.
  • Purpose: sending the code and the report you asked for.
  • Legal basis: your request (GDPR Article 6(1)(b)).

Marketing emails: only if you tick the separate checkbox, which is unticked by default. The emails tell you when Meta or Google change their tracking rules, with the fixes for your store, and share Margyn news. We record when you gave consent.

  • Legal basis: consent (GDPR Article 6(1)(a); Section 6 of Hungarian Act XLVIII of 2008).
  • Withdrawal: at any time, through the unsubscribe link in any marketing email or by writing to us (section 16). Withdrawal does not affect the report you already received.

How long we keep it:

  • The copy of the result used for the emailed report (Upstash): 24 hours, then deleted automatically.
  • The stored result and public report of each check (Supabase): 24 months from the check, then deleted automatically; on a removal request, within 3 working days.
  • The email code: 10 minutes.
  • Your email address and consent record: 12 months from the request, then deleted automatically.
  • Your IP address (for IPv6, its network prefix): used only as a keyed hash (HMAC with a secret key) to count requests against abuse; these counters expire within two hours. It is never stored with your email address.
  • Your email address is also counted, as a keyed hash in the same way, to limit how many codes one address can receive; that counter expires within two hours.

Bot protection: the forms may use Cloudflare Turnstile (Cloudflare, Inc.) to tell people from automated abuse. For this check Cloudflare processes technical data such as your IP address and browser details (legal basis: our legitimate interest in keeping the free tool available, GDPR Article 6(1)(f)).

Service providers for this feature: Vercel (website), Railway (the automated browser, EU region), Upstash (temporary storage of results and codes), Resend (email), Supabase (email address, consent record and public reports, EU), Cloudflare (bot protection) and Google (PageSpeed Insights).

6.10. AI assistants connected by a user (ChatGPT, Claude and other MCP clients)

This is optional and starts only when a user of the platform chooses it. A user can connect the Service to an AI assistant such as ChatGPT or Claude. The user signs in to the platform and approves the connection (OAuth 2.0); from then on the assistant can read that user's data in the platform when the user asks it a question.

  • What the assistant can receive: the answers to the user's questions (sales, profit, product, advertising and customer-group figures for the stores the user's account can access); the names of those stores and of the connected advertising accounts; and, where the user asks the assistant to create or save something, the text it saves in the platform (chart notes, competitor reports, style presets) and the images or videos it creates for the store.
  • What it does not receive: the user's password, payment card numbers, the access tokens and API keys of the connected store and advertising accounts, and the names, email addresses or phone numbers of individual shoppers. The tools return totals and groups, not individual shopper records.
  • Recipient: the AI provider behind the assistant the user chose: OpenAI (ChatGPT), Anthropic (Claude) or another provider if the user connects a different assistant. That provider receives what the assistant reads in order to answer, and handles it under its own terms and privacy policy, which the Provider does not control and which are part of the user's own agreement with it. OpenAI and Anthropic are based in the United States, so what the assistant reads may be processed there, under the provider's own safeguards and terms. The Provider sends data to an assistant only after a user has connected it, and only in answer to that user's request.
  • Access control: an assistant sees only the stores the connecting user's account can access, with that user's role; the viewer role cannot use the connection. Actions that create or change something (images, videos, saved notes and reports, style presets, a Performance Max refresh) run only when the user asks the assistant for them, and some need an owner or administrator role and an active subscription.
  • Duration and disconnecting: access tokens expire after one hour and can be renewed for up to 30 days. The user can disconnect an assistant at any time in the platform under Settings > MCP, and its access stops at once.
  • What the Provider keeps: a usage record of each request: which tool was called, by which user, for which store, the request settings (such as the date range), how long it took and whether it failed. It is kept in the Provider's product analytics (PostHog) for the period stated for PostHog analytics data in section 4.3. The answers returned to the assistant are not part of this record. Items created or saved at the user's request are stored with the Customer's other platform data, under section 4.3.
  • Purpose and legal basis: providing the connection the user asked for (GDPR Article 6(1)(b)) and, for the usage record, the Provider's legitimate interest in running and improving the Service (Article 6(1)(f)).

6.11. Catalog cards: designed images in the Customer's Meta catalog

This feature is optional and starts only when the Customer chooses it. Catalog cards lets the Customer design product images for its Meta catalog ads (for example the product photo with its price or a sale badge). A user with the owner or admin role can connect the Customer's Meta catalog on a feed's page in Catalog cards ("Connect your Meta catalog"). Facebook Login then asks the user to grant Margyn the catalog_management permission, and the business_management permission to list the catalogs of the businesses the user manages. The Customer can instead add the feed to its catalog by hand in Meta Commerce Manager; then no Facebook Login is needed and the Provider reads nothing from the catalog.

  • What the Provider reads from Meta: the names and IDs of the businesses the user manages and of their product catalogs (with the number of items in each); for the catalog the user chooses, its data sources (ID, name, type, which data feed a supplementary feed belongs to, and the address a supplementary feed is fetched from, so that the Provider recognises its own feed); and the result of Meta's latest fetches of the Provider's feed (time, number of items found and updated, number of errors and warnings), which the Provider reads when the feed's page is opened and does not store. Catalogs hold product data, not shopper data.
  • What the Provider writes: one supplementary data feed in the catalog the user chose, named "Margyn: " followed by the feed's name in Margyn, attached to the catalog's data feeds that do not have a supplementary feed yet. Meta fetches it every hour from the Provider's feed address, and the Provider may ask Meta to fetch it at once. For each product the Customer selected, the feed contains only the product ID, the address of the designed image (image_link) and, if the Customer set them, custom labels (custom_label_0 to custom_label_4). If the Customer had already added the same feed address to the catalog by hand, the Provider uses that feed instead of adding a second one.
  • What the Provider does not do: it does not create or delete catalogs, does not add or remove products, does not change product titles, descriptions, prices or availability, does not change or delete any other data feed, and does not write to a catalog the user did not choose. The only thing it ever deletes is the supplementary feed it added or took over.
  • What the Provider stores: the access token Meta issues, encrypted (AES-256-GCM) and never sent to the browser, with its expiry, the permissions granted and the catalogs the user selected in Meta's dialog; the Margyn user who connected; and, for each connected feed, the catalog's ID and name, the business's name, the IDs of the supplementary feed and of the data feeds it is attached to, the feed address, and when and by whom it was connected. The feed file is stored with the Customer's other Catalog cards data and can be opened without a login at a long, random address, because Meta fetches it from there.
  • Retention: when the user clicks "Disconnect", the Provider deletes the feed's connection details, and the token too if no other feed of the same store is still connected with it. When the user connects again, it replaces the token. It also deletes the token as soon as it finds that the token has expired or that Meta refuses it, which it checks when the feed's page is opened and when it lists the catalogs, adds the feed or removes it (Meta's long-lived tokens stop working after about 60 days, or at once if the user removes Margyn in their Facebook settings). The feed file is kept while the feed exists in Catalog cards and is deleted with the feed.
  • Disconnecting: the Customer can stop this at any time: (1) with "Disconnect" on the feed's page in Catalog cards, which removes the supplementary feed from the catalog and deletes the stored connection details and token as described under Retention (if the Meta login has expired, the user connects again first); (2) by deleting the feed in Meta Commerce Manager (Catalog > Data sources); or (3) by removing Margyn in Facebook Settings > Business integrations (https://www.facebook.com/settings?tab=business_tools). Option (3) ends all access that Facebook user gave Margyn, including a Meta Ads connection made with the same user (section 8.2), and the Provider can then no longer remove the feed, so delete it in Commerce Manager as well if the images should go. Once the feed is gone, Meta shows the products' own images again after it processes the change.
  • Use and sharing: the Provider uses this data only to deliver the images the Customer designed to the catalog the user chose, and to show the connection's status. It does not sell it, does not use it for advertising or profiling, and shares it with no one except the service providers below.
  • Service providers for this feature: Vercel (runs the connection and serves the feed file), Supabase (stores the token, the connection details and the feed file, EU), Upstash (a one-time code for the Facebook Login, kept for 15 minutes, with no data from Meta) and Sentry (error reports, which may contain a catalog ID or Meta's error message).
  • Purpose and legal basis: providing the feature the Customer asked for (GDPR Article 6(1)(b)).

7. Data Transfers and Data Processors (Subprocessors)

7.1. Data Processors We Use

The Provider uses the following external data processors to deliver the Service:

Database and application hosting:

Web application hosting:

Payment service:

  • Company: Stripe Payments Europe, Limited
  • Address: 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, D02 H210, Ireland
  • Registration Number: 533780
  • Data center: EU infrastructure
  • Email: privacy@stripe.com
  • Website: https://stripe.com

Invoicing service:

Email service:

  • Company: Resend Labs, Inc.
  • Address: 440 N Barranca Ave #7938, Covina, CA 91723, USA
  • Data center: USA (AWS infrastructure)
  • Email: support@resend.com
  • Website: https://resend.com
  • Data protection: Resend's data processing is GDPR-compliant, based on Standard Contractual Clauses (SCC)

AI image generation and analysis:

  • Company: Google Ireland Limited
  • Address: Gordon House, Barrow Street, Dublin 4, Ireland
  • Service: Google Gemini AI
  • Data center: EU and USA
  • Email: support-ireland@google.com
  • Website: https://ai.google.dev
  • Data protection: Google's data processing is GDPR-compliant, based on Standard Contractual Clauses (SCC)

Sentry (Error Tracking and Performance Monitoring):

  • Company: Functional Software, Inc. (Sentry)
  • Headquarters: San Francisco, USA
  • Server Location: Frankfurt, Germany (eu.sentry.io)
  • Email: support@sentry.io
  • Website: https://sentry.io
  • Data protection: GDPR-compliant, Standard Contractual Clauses (SCC)
  • Purpose: Application error tracking, performance monitoring, debugging
  • Data Transferred: Error messages, technical information, user context (email address, user ID, IP address), session replay (limited sampling, increased on errors), performance metrics, user interaction tracking, device and browser information
  • Session Replay: Records user interactions (clicks, scrolling, form fields) to reproduce steps leading to errors. High-risk data processing
  • Data Retention: 90 days (Sentry default policy)

Anthropic Claude AI (Artificial Intelligence Analysis):

  • Company: Anthropic PBC
  • Headquarters: San Francisco, USA
  • Server Location: USA
  • Email: privacy@anthropic.com
  • Website: https://www.anthropic.com
  • Data protection: GDPR-compliant, Standard Contractual Clauses (SCC)
  • Purpose: AI-powered business metrics analysis, report generation, explanations
  • Data Transferred: Aggregated business metrics (revenue, profit, margins), cost components, campaign performance indicators, product margin data - DOES NOT include customer personal data
  • AI Service Used: Anthropic Claude (current model version)
  • AI Operations Logging: Organization identifier, operation type, resources consumed, cost, operation duration, status - Stored indefinitely for organizational analytics and cost tracking
  • Anthropic Privacy: Anthropic does not use data sent via API to train models
  • Automated Decision-Making: AI analyses provide recommendations only; final decisions are always made by you (not automated decision-making per GDPR Article 22)

Slack (Team Collaboration and Report Delivery):

  • Company: Slack Technologies, LLC (owned by Salesforce)
  • Headquarters: San Francisco, USA
  • Server Location: USA
  • Email: feedback@slack.com
  • Website: https://slack.com
  • Data protection: GDPR-compliant, Standard Contractual Clauses (SCC)
  • Purpose: Automated report delivery, system alerts, team notifications
  • Data Transferred: OAuth workspace tokens, webhook URLs, business metrics and report content, organization identifiers, system monitoring alerts

Upstash Redis (Caching and Rate Limiting):

  • Company: Upstash, Inc.
  • Headquarters: USA
  • Server Location: EU (Frankfurt)
  • Email: support@upstash.com
  • Website: https://upstash.com
  • Purpose: API rate limiting, caching, request deduplication
  • Data Transferred: IP addresses (rate limit counters), request counters, temporary cache data, session tokens (transient storage)
  • Data Retention: 15 minutes - 24 hours TTL (depending on key type)
  • Data Residency: EU (Frankfurt server)

Tinybird (Analytics Data Warehouse):

  • Company: Tinybird
  • Headquarters: Spain
  • Server Location: EU
  • Email: support@tinybird.co
  • Website: https://www.tinybird.co
  • Purpose: Dashboard metrics processing, accelerating analytical queries
  • Data Transferred: Aggregated business metrics, dashboard statistics, time-series data - DOES NOT include customer personally identifiable information
  • Data Retention: Duration of organizational subscription

Railway (Application Hosting and Background Jobs):

  • Company: Railway Corp.
  • Headquarters: USA
  • Server Location: Configurable (EU regions in use)
  • Email: team@railway.app
  • Website: https://railway.app
  • Purpose: Application deployment, background job execution (sync services)
  • Function: Alternative hosting platform to Vercel, primarily for enterprise sync services
  • Data Transferred: data synchronised from the connected store and advertising platforms (for example orders, products, and Meta Ads campaign names and results) and the access tokens the synchronisation needs

Cloudflare Turnstile (Bot Protection):

  • Company: Cloudflare, Inc.
  • Address: 101 Townsend St, San Francisco, CA 94107, USA
  • Website: https://www.cloudflare.com
  • Purpose: telling people from automated abuse on the free tracking audit's forms (section 6.9)
  • Data Transferred: IP address, browser and device characteristics needed for the check
  • Safeguard: EU-US Data Privacy Framework and Standard Contractual Clauses (SCC)

SzámlaBridge (Invoice Intermediary Service):

  • Provider: SzámlaBridge
  • Headquarters: Hungary (Hungarian service)
  • Purpose: Generate Hungarian invoices and forward to Számlázz.hu
  • Data Flow: Margyn → SzámlaBridge → Számlázz.hu
  • Data Transferred: Invoice data (customer name, address, amount, line items)
  • Data Retention: 8 years (Hungarian accounting law)
  • Legal Basis: Legal obligation (GDPR Article 6(1)(c))

A Data Processing Agreement (DPA) is in effect between the Provider and all data processors.

Engaging new data processors: In case of engaging a new data processor, we inform Customers in advance via email.

7.2. Data Transfer to Third Countries

For certain services, personal data may be transferred outside the European Union to the United States of America:

United States:

  1. Sentry - Functional Software, Inc.

    • Server Location: EU (Frankfurt), but US company
    • Data Processing: Primarily within EU, but company registered in USA
    • Safeguard: Standard Contractual Clauses (SCC)
    • Note: PII data transfer (email, IP address, user ID)

  2. Anthropic Claude - Anthropic PBC

    • Data Processing: USA
    • Safeguard: Standard Contractual Clauses (SCC)
    • Note: Anthropic does not use API data for model training
    • Data Transferred: Only aggregated business metrics, no personal data

  3. Google Gemini AI - Google Ireland Limited

    • Data Processing: EU and USA
    • Safeguard: Standard Contractual Clauses (SCC)
    • Google provides GDPR-compliant data processing
    • Data Transferred: Product images, business metrics (aggregated)

  4. Resend - Resend Labs, Inc.

    • Email service servers operated by AWS USA infrastructure
    • Safeguard: Standard Contractual Clauses (SCC)
    • Data enjoys protection provided by GDPR provisions
    • Data Transferred: Email addresses, names, message payload

  5. Slack - Slack Technologies, LLC

    • Data Processing: USA
    • Safeguard: Standard Contractual Clauses (SCC)
    • Data Transferred: Business reports, organizational metrics

  6. Upstash - Upstash, Inc.

    • Company: USA, but servers in EU region
    • Data Residency: EU (Frankfurt)
    • Note: Data physically remains within EU

  7. Railway - Railway Corp.

    • Company: USA
    • Server Location: Configurable (EU regions in use)
    • Note: Data residency configured in EU

  8. Cloudflare - Cloudflare, Inc. (Turnstile bot protection, section 6.9)

    • Data Processing: global network, including the USA
    • Safeguard: EU-US Data Privacy Framework, Standard Contractual Clauses (SCC)
    • Data Transferred: IP address, browser and device characteristics

European Union:

  • Tinybird - Spain (EU member state, no additional safeguards required)
  • Supabase - Servers in EU (Frankfurt), no third country transfer
  • Stripe Payments Europe - Ireland (EU member state)
  • Számlázz.hu - Hungary (EU member state)

For future data transfers:

  • Prior notification to Customers
  • Application of Standard Contractual Clauses (SCC)
  • Compliance with EU Commission adequacy decisions

8. Processing Third-Party Data

IMPORTANT: It is the Customer's responsibility to only provide or upload personal data to the Service for which they have the appropriate legal basis and consent.

Third-party data:
If the Customer provides or uploads personal data of third parties (e.g., customers, employees, suppliers) to the Service, the Customer must:

  • Obtain necessary consents from third parties
  • Inform third parties that their data will be processed
  • Ensure third parties are aware of this Privacy Policy

Provider's limitation of liability:
The Provider is not responsible for unlawful processing of third-party data if:

  • The Customer did not obtain appropriate consents
  • The Customer did not properly inform third parties
  • The Customer uploaded data they were not authorized to use

If a third party legitimately objects to the processing of their data and credibly proves this, the Provider will immediately delete the data and inform the Customer.

8.1. Google Ads Data

When you connect Google Ads to Margyn, we access and store the following data:

Data We Collect:

  • Campaign performance metrics (impressions, clicks, spend, conversions)
  • Ad account information (account ID, name, currency, timezone)
  • Campaign names and structure
  • Demographic performance data (age, gender, device breakdowns)

How We Use This Data:

  • Calculate advertising ROI and return on ad spend (ROAS)
  • Display advertising performance in your dashboard
  • Determine net profit margins after accounting for advertising costs
  • Identify which campaigns drive profitable vs unprofitable sales
  • Enable trend analysis and historical reporting

Actions We May Perform (Only When You Request):

  • Pause or resume campaigns when you click the action button
  • Adjust campaign budgets when you enter a new budget amount

We Do NOT:

  • Create new campaigns or ads without your explicit request
  • Modify ad creative, targeting, or bidding strategies automatically
  • Share your Google Ads data with third parties
  • Access Google Ads accounts you haven't explicitly connected
  • Make any automated changes without your direct action

Data Security:

  • OAuth tokens are encrypted at rest using industry-standard encryption
  • Data is only accessible to the account owner who connected the integration
  • Access is isolated per user account with strict permission controls
  • Margyn's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy (https://developers.google.com/terms/api-services-user-data-policy), including the Limited Use requirements.
  • We use Google user data only to provide and improve the features you asked for (reporting, and the optional features below). We do not sell it, use it for advertising, or let people read it except as you allow, to follow the law, or to keep the service secure.
  • Full technical details available in Section 11 (Data Security)

Google Merchant Center (optional, only if you connect it):

  • What we read: your product list and Google's price benchmarks for those products.
  • What we write: your own custom labels (profit group, promotion, price range, price versus market, season), into a separate Margyn data source in your own Merchant Center account. Nothing is sent until you turn it on and click send.
  • What we use it for: to let you build Shopping campaigns around profit. We do not use it for anything else and do not share it with anyone.

Profit to Google Ads (optional): see section 6.6. Only for orders placed with the shopper's marketing consent, it sends the Google click ID and the order's ID, time, currency and profit (and, if you turn it on, its revenue). It sends no email address, phone number, name, address or IP address.

Revoking Access:
You can revoke our access to your Google Ads data at any time by:

  1. Disconnecting the integration in Margyn Settings → Integrations
  2. Revoking access directly at https://myaccount.google.com/permissions

Data Retention:

  • Historical advertising data is retained for trend analysis and reporting
  • When you disconnect, we stop syncing but retain historical data for your records
  • You can request full data deletion per Section 10 (Data Subject Rights)
  • Deleted data is permanently removed within 30 days

Legal Basis:

  • Contract Performance (GDPR Art. 6(1)(b)): Processing necessary to provide advertising analytics services
  • Legitimate Interest (GDPR Art. 6(1)(f)): Historical data retention for business continuity and your own records

8.2. Facebook/Meta Ads Data

When you connect Facebook/Meta Ads to Margyn, we access and store the following data:

Data We Collect:

  • Ad campaign performance metrics (impressions, clicks, spend, conversions)
  • Ad account information (account ID, name, currency, timezone)
  • Campaign and ad set structure
  • Demographic performance breakdowns (age, gender, location)
  • Page engagement metrics (when Facebook Pages are connected)

How We Use This Data:

  • Calculate advertising ROI and return on ad spend (ROAS)
  • Display advertising performance in your dashboard
  • Determine net profit margins after accounting for advertising costs
  • Identify which campaigns and demographics drive profitable sales
  • Show correlation between organic and paid social media reach
  • Enable trend analysis and historical reporting

Actions We May Perform (Only When You Request):

  • Pause or resume campaigns and ad sets when you click the action button
  • Adjust campaign budgets when you enter a new budget amount

We Do NOT:

  • Create new campaigns or ads without your explicit request
  • Modify ad creative or targeting automatically
  • Share your Meta Ads data with third parties
  • Access ad accounts you haven't explicitly connected
  • Make any automated changes without your direct action

Data Security:

  • OAuth tokens are encrypted at rest using industry-standard encryption
  • Data is only accessible to the account owner who connected the integration
  • Access is isolated per user account with strict permission controls
  • We comply with Meta's Platform Policy and Platform Terms
  • Full technical details available in Section 11 (Data Security)

Meta catalog (optional, only if you connect it in Catalog cards): see section 6.11. Margyn adds only its own supplementary data feed (product ID, designed image and optional custom labels) to the catalog you choose. It does not create or delete catalogs, add or remove products, or change product titles, prices or availability.

Revoking Access:
You can revoke our access to your Meta Ads data at any time by:

  1. Disconnecting the integration in Margyn Settings → Integrations
  2. Revoking access directly at https://www.facebook.com/settings?tab=business_tools

Data Retention:

  • Historical advertising data is retained for trend analysis and reporting
  • When you disconnect, we stop syncing but retain historical data for your records
  • You can request full data deletion per Section 10 (Data Subject Rights)
  • Deleted data is permanently removed within 30 days

Legal Basis:

  • Contract Performance (GDPR Art. 6(1)(b)): Processing necessary to provide advertising analytics services
  • Legitimate Interest (GDPR Art. 6(1)(f)): Historical data retention for business continuity and your own records

Facebook Lead Ads (Optional Feature):
If you use our optional Lead Ads feature, we additionally access:

  • Lead form submissions (name, email, phone, custom fields)
  • Form names and structure
  • Submission timestamps

This data is used solely to:

  • Import leads into Margyn for CRM purposes
  • Calculate cost per lead (CPL) metrics
  • Track lead → customer conversion rates
  • Display leads in your admin interface at /admin/facebook-leads

8.3. Klaviyo Data

Connecting Klaviyo is optional. You connect it on Klaviyo's own OAuth consent screen, and you can disconnect it at any time in Margyn (Integrations → Klaviyo → Settings → Disconnect). Once it is connected, we access and store the following data:

Data We Collect:

  • Klaviyo account information (account ID, currency, timezone, and the ID of the Klaviyo metric that records your store's orders)
  • Campaign, flow and message names, each message's channel (email or SMS), and each campaign message's send time
  • Per-message totals from Klaviyo's reporting, by day for flows (recipients, deliveries, bounces, unique opens, unique clicks, unsubscribes, spam complaints, conversions and their value, and SMS spend)
  • For orders Klaviyo credits to an email or SMS message: the order's ID, value and time, which campaign or flow message Klaviyo credits, Klaviyo's IDs for the order event and for the open or click behind the credit, and whether that touch was an open or a click. No customer names, emails, phone numbers, addresses or order contents are stored.

How We Use This Data:

  • Show each campaign's and flow's results and contribution margin next to your store's orders, on your own dashboard
  • Match orders to emails using the UTM tags on your store's own orders (the order-source data in section 5.1)
  • Show which of your store's orders Klaviyo itself attributes to each email (opens and clicks, or clicks only), next to Margyn's own matching

We Do NOT:

  • Send emails
  • Change your campaigns or flows
  • Write anything to your Klaviyo account
  • Store your subscribers' profile data
  • Store the content of your emails

Data Security:

  • Access is read-only: we request only the accounts:read, campaigns:read, flows:read, metrics:read and events:read scopes
  • To read each credited order's ID and value, Margyn receives Klaviyo's order events, which also contain the buyer's name, email, phone and address. These are read in memory and discarded at once; they are never stored or logged.
  • Access tokens are stored encrypted

Revoking Access:
You can revoke our access to your Klaviyo account at any time by:

  1. Disconnecting Klaviyo in Margyn (Integrations → Klaviyo → Settings → Disconnect). Margyn then asks Klaviyo to revoke its access and deletes the access tokens; if Klaviyo does not confirm, Margyn tells you so.
  2. Removing the Margyn app inside your Klaviyo account.

Data Retention:

  • After you disconnect, the figures already imported are no longer shown
  • They are deleted when your store is deleted from Margyn, or earlier on request per Section 10 (Data Subject Rights)

Legal Basis:

  • Contract Performance (GDPR Art. 6(1)(b)): processing necessary to provide the email reporting you asked for
  • Legitimate Interest (GDPR Art. 6(1)(f)): keeping the figures already imported after you disconnect, so that reconnecting restores your history

Klaviyo's own processing: Klaviyo is a separate controller of its own data and processes it under its own privacy policy: https://www.klaviyo.com/legal/privacy

9. Consent Withdrawal

How to withdraw your consent:

The Customer may withdraw consent given for using the Service at any time, without justification, through the following methods:

1. Account settings:

  • After login: Settings → Privacy
  • Toggles for enabling/disabling individual consents

2. Email unsubscribe:

  • Every marketing email contains an "Unsubscribe" button
  • Automatic unsubscription upon click

3. Via email:

  • Send a message to support@margyn.io
  • Specify which consent you wish to withdraw
  • Effective within 48 hours

4. Cookie settings:

  • Cookie banner → Manage settings
  • Any optional cookie can be disabled

Important notes:

  • Consent withdrawal does not affect the lawfulness of processing prior to withdrawal
  • Withdrawing certain consents (e.g., user account data) may limit or prevent Service usage
  • Mandatory processing (contract performance, legal obligation) cannot be withdrawn

10. Data Subject Rights

10.1. Rights Granted Under GDPR

Right of access (GDPR Article 15):
You may request information about which personal data we process about you.

Right to rectification (GDPR Article 16):
You may request correction or completion of inaccurate or incomplete data.

Right to erasure / "Right to be forgotten" (GDPR Article 17):
You may request deletion of your data if:

  • The data is no longer needed for the original purpose
  • You withdraw your consent
  • We processed your data unlawfully
  • Legal obligation requires it

Exception: Billing data cannot be deleted for 8 years (Hungarian Accounting Act).

Right to data portability (GDPR Article 20):
You may request your data in machine-readable format (JSON, CSV).

Right to object (GDPR Article 21):
You may object to processing based on legitimate interest (e.g., marketing).

Rights related to automated decision-making (GDPR Article 22):
Our platform does NOT use automated decision-making with profiling.

10.2. Exercising Your Rights

How to exercise your rights:

  1. Email: support@margyn.io
  2. After login: Account settings → Privacy
  3. In writing: 1143 Budapest, Eleonóra u. 8. 4/3, Hungary

Response deadline: 30 days (GDPR Article 12)
Cost: Free (we may charge for manifestly unfounded or excessive requests)

If your request concerns data from a store platform, the store owner is the data controller; where the platform does not notify us automatically (for example WooCommerce), please contact the store owner, who forwards it to us.

10.3. Right to Lodge a Complaint

If you believe we have violated your data protection rights, you may lodge a complaint with:

NAIH (National Authority for Data Protection and Freedom of Information):

Through court:
You may initiate civil proceedings in the court of your place of residence (GDPR Article 79).

11. Data Security

11.1. Technical Measures

Encryption:

  • In transit: TLS 1.3 (HTTPS)
  • At rest: AES-256 encryption (Supabase)
  • Passwords: Irreversibly encrypted

Access control:

  • Role-based permission management (owner, admin, analyst, viewer)
  • Two-factor authentication (2FA) support
  • Row Level Security (RLS) in Supabase

Backups:

  • Automatic daily backups (Supabase)
  • 30-day backup history
  • Geo-redundancy within the EU

11.2. Organizational Measures

  • Internal data protection policies
  • Employee confidentiality agreements
  • Regular security audits
  • Incident response plan

11.4. Platform Administrator Features

Admin Impersonation

Platform administrators may temporarily access user sessions for technical support and troubleshooting purposes:

Purpose: Technical support, troubleshooting, user training, customer service assistance

Logging: All admin access is logged:

  • Who (admin user ID)
  • When (timestamp)
  • Which user session (affected user)
  • What actions were performed (audit log)

Legal Basis: Legitimate interest (GDPR Article 6(1)(f)) - ensuring service quality and security

Restrictions:

  • Only when necessary
  • For minimal duration
  • Only authorized administrators
  • Strict access rules

Notification: Users will be informed of admin access upon request (audit log viewing)

Data Security: Admin access occurs through encrypted channels, all actions are logged

11.3. Data Breach Management

In case of a data breach (data leak, unauthorized access):

NAIH notification:

  • Deadline: Within 72 hours (GDPR Article 33)
  • Content: nature of breach, number of affected persons, expected consequences, measures taken

Data subject notification:

  • If the breach poses a high risk to data subject rights
  • In clear and plain language
  • Recommended measures (e.g., password change)

Documentation:

  • We record every incident
  • Annual report prepared for management

11.5. Data Protection Impact Assessment (DPIA)

We have conducted data protection impact assessments for the following high-risk processing activities on the platform:

Assessed Activities:

  • Session recording and replay (Sentry Session Replay, PostHog Session Recording)
  • Systematic user behavior tracking (PostHog automatic tracking, Sentry interaction trails)
  • Organization-level product measurement (server-side, no cookies, no user identifier; GDPR Art. 6(1)(f) legitimate interest — see the Cookie Policy section 3.5, and the right to object under Art. 21)
  • AI-powered business data analysis (Claude, Gemini metrics analysis)
  • Transfer of personal identifiers to third countries (USA - Sentry, Anthropic, Slack)

Risk Mitigation Measures:

  • Session replay with limited sampling (lower rate for normal usage, higher on errors)
  • IP address anonymization where possible
  • Data minimization - only necessary data transferred
  • Encrypted data transfer (TLS 1.3)
  • Standard Contractual Clauses with all US-based providers
  • Regular data protection audits
  • User consent requested for high-risk processing

DPIA Documentation: Full DPIA documentation is available upon request at support@margyn.io.

12. Cookie Usage

12.1. Cookie Categories

Strictly necessary cookies:

  • Session ID (maintaining login)
  • CSRF token (security)
  • Language and timezone preferences

Analytics cookies (with consent):

  • Google Analytics: page visit analysis
  • Vercel Analytics: performance measurement

Marketing cookies (with consent):

  • Meta Pixel: retargeting campaigns
  • Google Ads: conversion tracking

12.2. Cookie Management

Requesting consent:

  • Cookie banner appears on visit
  • Optional cookies only activate with consent
  • Can be modified at any time in settings

Deleting cookies:

  • Browser settings → Delete cookies
  • Account settings → Cookie settings → Revoke all

Cookie lifetime:

  • Session cookies: Deleted on browser close
  • Persistent cookies: Maximum 12 months

Detailed information:
For detailed cookie handling, see the Cookie Policy document: Cookie Policy

13. Data Processing Register (GDPR Article 30)

Interactic Media Kft. maintains detailed records of all data processing activities:

  • Categories of data processed
  • Purposes of processing
  • Categories of data subjects
  • Recipients of data transfers
  • Deadlines
  • Technical and organizational measures

Access: Available to NAIH upon request.

14. Protection of Children's Data

Our Service is not available to persons under 18 (B2B platform).

If we learn that a person under 18 has registered, we immediately delete their data.

15. Privacy Policy Updates

Updates:

  • Major changes: Email notification 30 days in advance
  • Minor changes: Website update + dashboard notification

Version control:

  • All versions remain available in archive
  • With version number and date marking

Last update: October 29, 2026

16. Contact

Data protection inquiries:

Email: support@margyn.io
Phone: [Optional]
Postal address: 1143 Budapest, Eleonóra u. 8. 4/3, Hungary

Official inquiries, complaints:
Please send in writing to:
Interactic Media Kft.
1143 Budapest, Eleonóra u. 8. 4/3, Hungary
Marked "Data Protection Request"

Appendices

Appendix 1: Data Processing Agreement template (DPA)
Appendix 2: Subprocessor list
Appendix 3: Data retention table
Appendix 4: NAIH complaint filing guide

Interactic Media Kft.
Budapest, November 1, 2025

Declaration

This Privacy Policy was prepared based on the following official sources:

Disclaimer: This document does not constitute legal advice. For specific legal questions, consult a data protection expert or attorney.

Margyn – Actual Profit Analytics | Shopify, UNAS & WooCommerce (Beta)