Privacy Policy

This Privacy Policy describes how Selgeo (Apliteni OÜ; “we”, “us”, “our”) collects, uses and protects personal data of users of our platform (merchants and partners) as well as visitors to merchant websites in the context of our attribution services.

We operate in line with the EU General Data Protection Regulation (GDPR) and the ePrivacy Directive, building Privacy by Design into our cookie-free attribution architecture.

1. Who is the data controller?

Selgeo acts as the Controller for merchant registration data, Global Partner Account data and tax information.

• Legal entity: Apliteni OÜ
• Jurisdiction: Estonia (European Union)
• Contact email: contact@selgeo.com

For merchant customers' data received from Stripe for attribution purposes we act as aProcessor and handle that data solely on the merchant's instructions.

2. What data we collect and on what basis

We only collect data that is necessary to operate the platform and to comply with EU law.

3. Our cookieless technology (ePrivacy)

• No cookies. Our JS snippet on merchant websites does not set any cookies (first-party or third-party).
• sessionStorage. We store the Click ID and technical tokens in the browser'ssessionStorage. This data lives only within a single tab and is cleared when the tab closes.
• Server-side. Attribution runs on our servers via Stripe webhooks. We do not use browser fingerprinting or cross-site tracking.

4. How we use data from Stripe

The Stripe integration is used solely to:

1. Determine whether a conversion occurred and its amount, in order to calculate commissions.
2. Automatically synchronise promotion codes.
3. Check the status of refunds so we can adjust commissions accordingly.

We do not have access to full card numbers, CVV codes or payment history unrelated to your partner programme.

5. Where your data is stored (data residency)

EU data security is our priority.

• Localisation. All personal data of EU data subjects is stored exclusively on servers within the European Economic Area (EEA).
• Infrastructure. We use secure EEA-based data centres.
• Transfers. We do not transfer data outside the EEA without Standard Contractual Clauses (SCCs) approved by the European Commission.

6. Who receives your data (sub-processors)

We do not sell your data. It may only be shared with a limited set of recipients:

1. Merchants and partners — mutual data exchange (email, reports) necessary to operate payouts.
2. Stripe — payment infrastructure. You connect your own Stripe account (Stripe is your own payment provider), and Stripe also processes your payment for the Selgeo subscription. It is not a Selgeo sub-processor of Merchant data — see the categorised list below.
3. Tax authorities — as part of DAC7 and VAT VIES reporting, where EU law requires it.
4. Hosting providers — operating our servers inside the EU.
5. Email delivery provider — sending transactional emails (account, payout and notification messages) on our behalf.

A current, named list of sub-processors with locations and transfer mechanisms is published atselgeo.com/sub-processors and updated at least fourteen days before any change.

7. Data retention

We keep data only as long as needed for the purposes in Section 2:

• Accounts. Until the user deletes the account, plus 30 days for anonymisation.
• Accounting data. 7 years (EU financial regulations).
• DAC7 data. 10 years from the reporting period.
• Attribution logs. The merchant's attribution window plus 90 days.

8. Your GDPR rights

You have the full set of rights over your data:

• Access and portability — export your data in JSON or CSV from the dashboard.
• Right to be forgotten — delete your account and anonymise all data not required by law.
• Rectification — edit your profile and tax details in real time.
• Object (Art. 21) — where we process your data on the basis of our legitimate interests (Art. 6(1)(f) — for example attribution accuracy and fraud protection), you may object at any time on grounds relating to your particular situation. We will then stop unless we can demonstrate compelling legitimate grounds that override your interests, or the processing is needed to establish, exercise, or defend legal claims.
• Restriction (Art. 18) — you may ask us to restrict the processing of your data in the circumstances set out in Article 18 GDPR.
• Withdraw consent (Art. 7(3)) — where processing is based on your consent, you may withdraw it at any time; withdrawal does not affect the lawfulness of processing carried out before then.
• Right to complain — you can contact your local supervisory authority. In Estonia, that is Andmekaitse Inspektsioon (the Estonian Data Protection Inspectorate).

9. Security and incident notification

We apply strict protective measures under Art. 32 GDPR:

• Encryption — TLS 1.3 in transit, AES-256 at rest.
• Workspace isolation — data is isolated at the Workspace level.
• Notification. Where we act as controller, we will notify the supervisory authority (Andmekaitse Inspektsioon) within 72 hours where the incident poses a risk to the rights and freedoms of data subjects, and we will notify affected individuals without undue delay where the incident is likely to result in a high risk to them. Where we process data on a merchant's behalf, we will notify that merchant without undue delay, and it is the merchant, as controller, who notifies the supervisory authority and the individuals concerned.

10. Contact form on selgeo.com

If you send us a message through the contact form on selgeo.com, we process:

• Name and email address — to identify you and reply to your enquiry. Legal basis: legitimate interest (Art. 6(1)(f)) — responding to an enquiry you chose to send us.
• Message content — to understand and answer your enquiry. Legal basis: legitimate interest (Art. 6(1)(f)) — responding to an enquiry you chose to send us.
• HMAC-SHA256 hash of your IP address (with a server-side pepper — the original IP is never stored) — to detect spam and abuse. Legal basis: legitimate interest (Art. 6(1)(f)).
• Submission timestamp — to handle and triage your enquiry. Legal basis: legitimate interest (Art. 6(1)(f)).

Retention. 12 months from your last contact, unless your enquiry becomes part of an ongoing customer relationship.

Your rights. Emailcontact@selgeo.com to access or delete your contact record. Because we rely on legitimate interest, you may object to this processing at any time on grounds relating to your particular situation (Art. 21).

11. Cookies and analytics on selgeo.com

We use our own privacy-focused analytics (Lessly, a platform operated by the same company as Selgeo, Apliteni OÜ) on this marketing site to understand which channels bring visitors and how many go on to sign up. It runs in two modes, and the mode depends on your choice in our cookie banner:

• Before you accept, or if you decline. We record an anonymous, cookieless page view: the page address, the site that referred you, and any campaign parameters (for example UTM tags) in your link. No cookies are set or read, and no visitor or session identifier is created — we cannot link one page view to another, or to you. Legal basis: legitimate interest in understanding aggregate traffic to our own site (Art. 6(1)(f)). Because nothing is stored on or read from your device, this does not require consent under the ePrivacy Directive.
• After you accept the “statistics” category. Analytics cookies are set, which lets us recognise a returning visit and follow a visit through to sign-up. Legal basis: your consent (Art. 6(1)(a)).

• Only after you accept. The lessly_consent cookie simply records your choice and is strictly necessary. The analytics cookies (_lt_aid, _lt_sid) are set only if you accept the statistics category.
• Withdraw any time. Reopen the cookie preferences from the banner to change or withdraw your choice. Withdrawing deletes _lt_aid and _lt_sid and returns measurement to the anonymous, cookieless mode described above.

Lessly is operated by the same company as Selgeo (Apliteni OÜ) and runs on the same EU infrastructure, so your analytics data stays within Apliteni and the EEA — it is not shared with an independent third-party analytics provider.

On-site surveys. After you accept the statistics category, we may show you a short survey on this site — for example, asking what is holding you back from trying Selgeo. Answering is optional and you can close the survey without answering. If you do answer, we store your answers together with the same analytics visitor identifier (_lt_aid) and the page you were on — no name, email address or IP address — in Lessly, under the same conditions as the analytics data above. Withdrawing your consent stops the survey from appearing. Legal basis: your consent (Art. 6(1)(a)).

12. Product analytics in the Selgeo app (app.selgeo.com)

Inside the signed-in app we record a small set of product-analytics events about how merchants use the dashboard — for example which screens you open, which step of the setup wizard you reach, when you connect Stripe, and when you follow a link out to our documentation. We use this to understand where people get stuck so we can improve onboarding and the product. This is separate from the cookie-free attribution we provide to merchants, and separate from the marketing analytics on selgeo.com described in Section 11.

• What we record. A fixed list of about fifteen events, each with a small, closed set of technical fields (for example the name of the screen as a route pattern, the wizard step, the workspace mode, the chosen plan). We never record free-text you type, and page identifiers are stored as patterns, so no individual record identifier ends up in the analytics.
• Keyed to your account, not your device. Events are recorded on our servers against your merchant account. Nothing is stored on or read from your device — no cookies, no local storage. Because nothing is stored on or read from your device, this does not require consent under the ePrivacy Directive. Legal basis: legitimate interest in improving our own product for our business customers (Art. 6(1)(f)).
• Where it goes. This data stays in the same EU database (Google Cloud, EEA) as the rest of your workspace. It is not sent to any third-party analytics provider, and it is not sent to Lessly.
• Retention. Up to 400 days, after which events are permanently deleted.
• In-app feedback prompts and the feedback form. Separately from the events above, the app has a feedback form (for merchants and for partners) and the dashboard occasionally shows a short prompt — for example a "how likely are you to recommend Selgeo?" question with an optional comment. Using either is optional. If you do, we store what you send, including any text you type, against your account, send it to our product team by email, and also store it with Lessly (operated by the same company, Apliteni OÜ, in the EEA) so we can follow up on it. Answers are anonymised when your account is deleted. Legal basis: legitimate interest in understanding how our business customers experience the product (Art. 6(1)(f)); the right to object below applies.
• Your right to object (Art. 21). You may object to this processing at any time on grounds relating to your particular situation — emailcontact@selgeo.com. When you object we stop the processing: we switch off event recording for your account and delete the events already collected.

13. Waitlist sign-up on selgeo.com

If you join our waitlist on selgeo.com, we process:

• Email address — to add you to our announcement list and let you know when a place opens or the product is ready. Legal basis: your consent (Art. 6(1)(a)), given when you submit the waitlist form.
• Sign-up source and date — so we can see which channels bring sign-ups. Legal basis: legitimate interest (Art. 6(1)(f)).

We share your email address with MailerLite Limited (Ireland, European Union), our email-marketing provider, which manages the list and delivers these announcements on our behalf. MailerLite stores the data primarily in the EU under its Data Processing Agreement; where it engages US-based sub-processors it relies on the EU-US Data Privacy Framework and the Standard Contractual Clauses for those transfers.

Retention. Until you unsubscribe or ask us to remove you, and in any case no longer than 12 months from your last interaction. Every announcement email carries a one-click unsubscribe link.

Your rights. Unsubscribe from any email, or contactcontact@selgeo.com to be removed. You can withdraw your consent at any time; withdrawal does not affect processing carried out before then.

Effective 3 September 2026. Contact:contact@selgeo.com.