Privacy Policy

Last updated: February 2026

EULabel ("we", "our" or "the app") is a Shopify application that helps merchants make their food products compliant with EU Food Information Regulation (FIC/LMIV). This privacy policy explains how we handle your data when using our service.

Controller

Controller within the meaning of the GDPR:

Robin Spanier Softwareentwicklung
Cloefstraße 6, 66693 Orscholz, Germany
Email: robin.spanier@robspan.de

A Data Protection Officer is not required pursuant to § 38 BDSG (fewer than 20 persons engaged in automated data processing).

Data We Access

To provide LMIV compliance services, EULabel accesses the following data from your Shopify store:

• Products: Product titles, descriptions and metafields for storing and displaying LMIV data (nutritional values, ingredients, allergens)
• Metafields: We create and manage metafields in the "lmiv" namespace for storing food information
• Shop information: Basic shop data for authentication and subscription management

Legal Bases for Processing

We process your data on the following legal bases:

• Session/authentication: Art. 6(1)(b) GDPR (performance of a contract) — required to operate the app and authenticate your Shopify store.
• Billing/credits: Art. 6(1)(b) GDPR (performance of a contract) — required to manage your subscription and scan/translation credits.
• Usage audit log: Art. 6(1)(f) GDPR (legitimate interest) — our legitimate interest in abuse prevention and billing verification.
• AI processing (scan/translation): Art. 6(1)(b) GDPR (performance of a contract) — required to provide the label scanning and translation services you have requested.

Data We Store

EULabel was designed with privacy in mind. We minimize data storage to the absolute minimum required:

What we store

• Session tokens: Required for app functionality and authentication with your Shopify store
• Credit data: Your scan credit balance and purchase history for billing
• Shop domain: To identify your store
• Usage audit log: Records of scan and translation events for billing verification (shop domain, event type, timestamp). Anonymized upon app uninstallation or GDPR request (see Data Retention).

What we do NOT store

• We do NOT store any customer data
• We do NOT store any product content on our servers
• We do NOT use any tracking cookies
• We do not share your data with advertisers, data brokers, or other commercial third parties. Data is only transferred to the service providers listed under "Third-Party Services" below.

How We Process Data

1. LMIV data: All nutritional and product information is stored directly in Shopify metafields, not on our servers.
2. Automatic label scan: When you upload a label image, it is sent to the Google Gemini API to automatically extract nutritional values, ingredients, allergens and other mandatory LMIV information. The image is used exclusively for this one-time processing and is not stored by us. The extracted data is saved as Shopify metafields in your store.
3. Automatic translation: When using the translation feature, your LMIV text data (ingredients, storage instructions, warnings, etc.) is sent to the Google Gemini API to produce translations into the desired EU languages. The texts are used exclusively for this one-time processing. The translations are stored as metafields in your Shopify store.
4. Compliance checking: Validation is performed in real time in the browser. No product data is permanently stored on our servers.
5. Nutri-Score: The calculation is performed client-side based on the entered nutritional data.
6. Theme blocks: Storefront display is rendered directly via Shopify's Theme Extension system without routing through our servers.

AI Processing and Data Quality

Important notice: When using the automatic label scan and the translation feature, your data is processed by AI technology (Google Gemini). This AI processing is subject to inherent limitations:

• AI-generated results (scan data, translations) may be inaccurate, incomplete, or incorrect
• Allergen information may be incorrectly detected, missed, or confused — this is safety-critical
• Nutritional values may deviate from actual values
• Translations may incorrectly translate technical terms or omit mandatory notices

We accept no responsibility for the accuracy of AI-generated data. All AI results must be manually reviewed before publication. Responsibility for the accuracy of all food information lies with the food business operator under EU Regulation 1169/2011 (LMIV).

Data Retention

• Session data: Stored only while the app is installed. Deleted immediately upon uninstallation.
• Credit and purchase data: Upon uninstallation or GDPR request, this data is anonymized (shop domain replaced with a non-reversible hash). The anonymized billing records are retained for up to 10 years in accordance with German commercial and tax law retention obligations (§ 147 AO, § 257 HGB). Legal basis: Art. 17(3)(b) GDPR (legal retention obligation).
• LMIV metafields: These remain in your Shopify store and can be edited or deleted by you at any time. Uninstalling the app does NOT delete the metafields. You must manually remove metafields in Shopify if needed.
• Usage logs: Upon uninstallation or GDPR request, usage logs are anonymized (shop domain hashed, product IDs removed) and retained for billing verification purposes (§ 147 AO).

Your Rights

Under the GDPR, you have the following rights regarding your personal data:

• Right of access (Art. 15 GDPR): You have the right to obtain confirmation as to whether personal data concerning you is being processed, and to request access to that data.
• Right to rectification (Art. 16 GDPR): You have the right to request the correction of inaccurate personal data without undue delay.
• Right to erasure (Art. 17 GDPR): You have the right to request the deletion of your personal data. Uninstalling the app deletes all stored data. We also respond to Shopify GDPR webhooks.
• Right to restriction of processing (Art. 18 GDPR): You have the right to request the restriction of processing of your personal data under certain conditions.
• Right to data portability (Art. 20 GDPR): You have the right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to object (Art. 21 GDPR): You have the right to object to the processing of your personal data at any time on grounds relating to your particular situation, where the processing is based on Art. 6(1)(f) GDPR (legitimate interest).

Right to withdraw consent

Where processing is based on consent, you have the right to withdraw that consent at any time. The lawfulness of processing carried out prior to withdrawal remains unaffected.

Right to lodge a complaint (Art. 77 GDPR)

You have the right to lodge a complaint with a supervisory authority. The competent supervisory authority is:

Unabhängiges Datenschutzzentrum Saarland
Fritz-Dobisch-Straße 12, 66111 Saarbrücken, Germany
poststelle@datenschutz.saarland.de

GDPR principles

EULabel is designed to be GDPR-compliant:

• Data minimization (Art. 5): We only access the minimum data required.
• Purpose limitation (Art. 5): Data is used solely for LMIV compliance purposes.

Third-Party Services

EULabel uses the following third-party services:

• Shopify: For API access, billing and data storage (metafields). Subject to Shopify's privacy policy.
• Google (USA): For automatic label recognition and automatic translation of LMIV data. When using the scan feature, the uploaded label image is sent to the Google Gemini API; when using the translation feature, your LMIV text data is sent to the Google Gemini API. Google processes the data exclusively for one-time processing and does not store it permanently (when using the API). Google processes data as a processor under Art. 28 GDPR on the basis of a Data Processing Addendum. Google's privacy policy: policies.google.com/privacy.
• Hosting provider: For operating the application. Has no access to your store data.

Data transfer to the USA

Data transfer to the USA is based on the European Commission's adequacy decision for the EU-US Data Privacy Framework (Art. 45(1) GDPR). Google LLC is a certified participant in the EU-US Data Privacy Framework. Additionally, Standard Contractual Clauses (Art. 46(2)(c) GDPR) under Google's Data Processing Addendum serve as a supplementary safeguard.

Beyond these service providers, we do not share your data with any other third parties, advertisers, or data brokers.

Automated Decision-Making

No automated decision-making within the meaning of Art. 22 GDPR takes place. The compliance score is purely informational and has no legal effects.

Obligation to Provide Data

Providing data is contractually required to use the app. Without providing shop data, the service cannot be rendered.

Security

We take security seriously:

• All communication is encrypted with HTTPS/TLS
• We use Shopify's secure OAuth for authentication
• Session tokens are stored securely and encrypted
• We follow Shopify's security best practices
• Input data is validated and sanitized

Deleting Your Data

To delete all data associated with your store:

1. Navigate to your Shopify admin panel
2. Go to Settings → Apps and sales channels
3. Find EULabel and click "Uninstall"

Upon uninstallation, all session and subscription data is immediately and permanently deleted. LMIV metafields remain in your store and can be deleted manually.

Applicable Law

This privacy policy is governed by the laws of the Federal Republic of Germany. Disputes are subject to the jurisdiction of the German courts.

Changes to This Policy

We may update this privacy policy from time to time. In the event of material changes, we will notify you through the app. Continued use of the app after changes constitutes acceptance of the updated policy.

Contact

If you have questions about this privacy policy or how we handle your data, please contact us:

Robin Spanier Softwareentwicklung
Cloefstraße 6, 66693 Orscholz, Germany
Email: robin.spanier@robspan.de

We aim to respond to all privacy-related inquiries within 48 hours.