This notice explains how Wintry Ltd collects and uses personal data, and the rights you have. It covers our website at wintry.io and the Wintry service at app.wintry.io (the “Service”).

Wintry Ltd is registered in England and Wales, company number 17508937, with its registered office at 66 Paul Street, London, EC2A 4NA, United Kingdom. For any question about this notice or your personal data, email support@wintry.io.

1. Our two roles

We handle two kinds of personal data, and our role is different for each.

Account Data is the information we collect to run your Wintry account: who you are, how you sign in, your plan, and how you use the Service. We decide how this data is used, so we are its controller. Sections 2 to 5 cover it.

Store Data is the content of your Square account that we back up for you, such as your items, customers, team members and invoices. It contains personal data about your customers and staff. The business that uses Wintry decides why that data is held and how it is used, so the business is its controller and we are its processor. We handle Store Data only on the business’s instructions and under our Data Processing Agreement. Section 6 summarises it.

If you are a customer or employee of a business that uses Wintry and have a question about your data, please contact that business. If you contact us, we will pass your request to them.

2. Account Data we collect

Sign-in details. Your name, email address and the sign-in method you use. If you sign in with a provider such as Google or Apple, that provider shares your name and email address with us. Our sign-in provider, Clerk, holds your password, if you set one, only as a one-way hash, and holds any passkeys. We never see your password.

Square connection details. Your Square business name, merchant ID and location names, and the access tokens Square issues to us, which we store encrypted.

Billing details. Your Stripe customer ID, plan, billing status and subscription dates. Stripe holds your payment card and billing address. We never receive full card numbers.

Service activity. Records of the backups and restores run on your account, when they ran, what they covered and whether they succeeded, together with the technical logs and error reports needed to run the Service.

Support and feedback. Messages you send us by email or through the in-app feedback and support form, with your name and email address so that we can reply.

Website and app usage. Technical information your browser sends, such as your IP address and browser type, when you visit our website or use the app. Section 8 explains cookies.

3. How we use Account Data and our lawful bases

Our contract is with the business that uses Wintry. Where you are that business yourself, for example as a sole trader, we rely on performing that contract with you. Where you use Wintry for a business, we rely on our legitimate interest in providing the Service to that business. Below, “our contract” refers to whichever of these applies to you.

• To provide the Service: creating your account, connecting to Square, running backups and restores, showing your history and answering support requests. Lawful basis: our contract.

• To bill you: managing your subscription and handling refunds. Lawful basis: our contract, and our legal obligation to keep financial records.

• To keep the Service secure and reliable: monitoring for errors and attacks, investigating incidents, and keeping records of restores and deletions. Lawful basis: our legitimate interest in running a secure and reliable service, and in some cases our legal obligations.

• To tell you about the Service: emails about your account, plan, backups, security and changes to our terms. Lawful basis: our contract, and our legitimate interest in keeping you informed.

• To comply with the law: responding to lawful requests from authorities and meeting our obligations as a company. Lawful basis: legal obligation.

We do not send marketing emails without your consent, and you can opt out of any we send. We do not sell personal data, use it for advertising, or make decisions about you based solely on automated processing that have legal or similarly significant effects.

You need to provide your sign-in and billing details to use the Service. Without them, we cannot create your account or provide a plan.

4. Who we share Account Data with

We use service providers to run Wintry. Each processes personal data only on our instructions, under a contract that requires it to protect the data:

• Google hosts the Service and stores backups on Google Cloud, and provides our email through Google Workspace.

• PlanetScale hosts our database.

• Temporal runs the jobs that perform backups and restores.

• Clerk provides sign-in.

• Sentry receives error reports and messages sent through the in-app feedback and support form.

• AI tools from our technology providers help us investigate and fix errors in the Service. They receive only the details needed to look into a specific problem, and they do not use your data to train their AI models. They delete it on their own schedules, except that they may keep content their safety systems flag for longer, under their own terms.

• Framer hosts our website and provides its analytics.

Stripe. When you pay for Wintry, Stripe’s affiliate Sold through Link, LLC (Onelink) acts as merchant of record for your purchase. Stripe decides for itself how it uses your payment data for that purchase, including for receipts, tax, fraud prevention and legal compliance, and handles requests about that data directly. Stripe’s privacy policy describes this.

We also share personal data where the law requires it, to protect our rights or someone’s safety, or with a buyer if our business is sold. We will tell you about a legal demand for your data unless the law prohibits it.

We share nothing with Square beyond what is needed to operate the connection you authorised.

The providers that can process Store Data are listed on our Sub-processors page at wintry.io/legal/sub-processors.

5. How long we keep Account Data

• Account and connection details: until your account is closed, then deleted, except for records we must keep for the reasons below.

• Billing records: for as long as UK company and tax law requires.

• Service activity: deleted with your Store Data, as our Terms of Service describe. We keep a record of each deletion for as long as Square may ask us to confirm it.

• Support messages: for as long as we need them to deal with your request and any follow-up.

• Technical logs and error reports: they expire automatically after a limited period, within the deletion periods in our Terms of Service.

6. Store Data

Our Data Processing Agreement fully describes how we process Store Data. In summary:

What it is. Copies of the Square data you authorise us to read when you connect: items and catalog, stock counts, customers and customer groups, team members, shifts and labour settings, locations and business profile, invoices, subscriptions, gift cards, loyalty, devices, online store sites, checkout settings, appointments and booking profiles, vendors, and custom attributes. It can include customers’ names, contact details, addresses, notes, invoices, bookings, loyalty records, gift card numbers and balances, and staff names, contact details, pay rates, shift records and declared tips. We do not request your payments, payouts, orders or bank accounts, and Square does not share full payment card numbers with apps.

Why we process it. Only to back it up, show it to the business, restore it and export it when the business asks.

Who can access it. Our systems, the sub-processors on our Sub-processors page, and the business. Our staff access Store Data only when the business asks for help with it, when we need to investigate a problem with the Service, or when the law requires it.

How long we keep it. While the business’s plan is active and its Square account is connected, and then as our Terms of Service describe.

What we never do with it. Sell it, use it for advertising, contact the people in it, or use it to train AI models.

7. International transfers

Wintry runs on Google Cloud in the United States, in the us-central1 region in Iowa, and our other providers also process data in the United States. Personal data about people in the UK is therefore transferred to the United States.

For these transfers, we rely on the UK Extension to the EU-US Data Privacy Framework where a provider is certified under it, and otherwise on the International Data Transfer Addendum to the EU Standard Contractual Clauses issued under UK law. Where a provider is established in the European Economic Area, we rely on UK adequacy regulations, and the provider’s data processing terms govern its onward transfers. Our Sub-processors page states the mechanism for each provider that handles Store Data. You can ask us which mechanism applies to any other provider, and for a copy of the safeguards we rely on.

If you are in Canada or Australia, your data is also stored and processed in the United States, where authorities may be able to access it under US law.

8. Cookies and similar technologies

Our website uses Framer’s built-in analytics, which counts visits without using cookies to identify you.

The app uses only:

• cookies set by Clerk that keep you signed in;

• cookies set by Stripe’s payment software on the plan and payment steps, which Stripe uses to prevent fraud; and

• storage in your browser that remembers your display preferences and where you are in the app.

These are either strictly necessary to provide the app or remember choices you make in it, so we do not ask for your consent to use them. You can block or delete them in your browser, but the app may then not work as expected.

9. Security

We protect personal data with encryption in transit and at rest, access controls and monitoring. Our Security page describes the measures we use. If a security incident affects your personal data, we will tell you without undue delay and, where the law requires, notify the relevant authority.

10. Your rights

You have the right to ask for a copy of your personal data, to have it corrected or deleted, to restrict how we use it, and to receive it in a portable format. Where we rely on your consent, you can withdraw it at any time.

You also have the right to object at any time to our use of your personal data based on our legitimate interests.

To exercise a right, email support@wintry.io. We will respond within one month. If a request is complex, the law allows us up to two further months, and we will tell you if we need them. We may ask you to confirm your identity first.

If your request concerns Store Data that a business holds about you, we will pass it to that business, because it is the controller of that data.

11. Complaints

If you are unhappy with how we have handled your personal data, email support@wintry.io with “Complaint” in the subject line. We will acknowledge your complaint within 30 days, look into it without undue delay, keep you informed, and tell you the outcome.

If you are in the UK, you also have the right to complain to the Information Commission, formerly the Information Commissioner’s Office, at ico.org.uk. In Australia, you can complain to the Office of the Australian Information Commissioner at oaic.gov.au. In Canada, you can complain to the Office of the Privacy Commissioner of Canada at priv.gc.ca.

12. Regional information

United States. Where a US state privacy law applies to a business using Wintry, we act as that business’s service provider or processor for Store Data. We do not sell or share personal data for cross-context behavioural advertising, and we do not use Store Data for any purpose other than providing the Service.

Canada. We process Account Data and Store Data in the United States. A business in Canada remains accountable under PIPEDA for the personal information in its Square account, and our Data Processing Agreement gives that information a comparable level of protection. Wintry is not available to businesses located in Quebec.

Australia. Account Data and Store Data are disclosed to recipients in the United States. A business using Wintry that is bound by the Australian Privacy Principles remains responsible for that disclosure, and our Data Processing Agreement contains the commitments it relies on.

13. Children

Wintry is a business service and is not intended for anyone under 18. We do not knowingly collect personal data from children, and we will delete any account we find belongs to one.

14. Changes to this notice

We will update this notice when our practices change. The date of the current version is shown at the top of this page, and earlier versions are available at wintry.io/legal. If a change materially affects how we use your Account Data, we will email you before it takes effect.