Privacy Policy

Effective Date: 22 April 2026

1. Introduction

This Privacy Policy explains how CES TS Software Ltd (“we”, “us”, “our”) collects, uses, and protects personal data in connection with our application available on the Clover platform (the “App”). This App is intended for use by business users (“Merchants”) and not for personal, family, or household purposes.

2. Data We Collect

• Merchant Information: Name, business name, business address, email address, and phone number.
• Transaction Data: Transaction amounts, timestamps, order details, and payment status. We do not collect or store full cardholder data.
• Device & Technical Data: Device identifiers, IP address, operating system, app version, and usage logs.
• Support & Communication Data: Information provided when contacting support, including messages and attachments.

3. Sources of Personal Data

We collect personal data from Merchants directly, the Clover platform, and payment processors and service providers integrated with the App.

4. How We Use Personal Data

To provide and operate the App; process and display transaction data; provide customer support; improve and develop our services; ensure security and prevent fraud; and comply with legal and regulatory obligations.

5. Legal Basis for Processing

Contractual necessity, legitimate interests, and legal obligations.

6. Sharing of Personal Data

We may share personal data with payment processors, cloud hosting providers, IT/support providers, professional advisers, and regulatory authorities where required. We do not sell personal data.

7. International Data Transfers

Where personal data is transferred outside of the UK or EEA, appropriate safeguards such as Standard Contractual Clauses are used.

8. Data Retention

• Transaction data is retained for up to 6-7 years.
• Support data is retained as needed.
• Technical logs are retained for a limited period.

9. Cookies and Tracking

Our website may use cookies. Users can manage or disable cookies through browser settings.

10. Children's Data

The App is not intended for individuals under 18, and we do not knowingly collect data from minors.

11. Your Rights

You have the right to access, correct, delete, restrict, or object to processing, and to data portability. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO).

12. GDPR and Data Protection

12.1 Data Protection Officer

Our appointed GDPR Data Protection Officer (DPO) can be contacted by email at dpo@cessoftware.com for any matters relating to GDPR. The DPO is responsible for maintaining records of GDPR-related activities, including meetings, data breaches, and employee training.

12.2 GDPR Commitment

CES Software adheres to GDPR requirements applicable to small businesses (fewer than 250 employees).

12.3 Data Security Measures

• We take reasonable steps to safeguard data both physically and electronically.
• Paper records are securely stored and access restricted to authorised staff.
• Electronic systems are password protected and secured by firewalls and other safeguards.
• We maintain a register of devices and storage locations containing sensitive data.

12.4 Your Additional Rights

You may request details of data held, request corrections, restrict usage, or request deletion. We may retain necessary data for legal and business purposes such as invoicing and credit control.

12.5 Third Parties

We require suppliers and partners to comply with GDPR and will not share data without consent unless legally required.

13. Changes to This Policy

We may update this Privacy Policy and will notify merchants via app notifications or email.

14. Contact Us

CES TS Software Ltd
39 Lindsey Street
Epping, Essex, CM16 6RB
Tel: 01992 564645