Privacy Policy – "Levamio Accessibility Check" (Shopify app)

Depending on the language, the app appears under a translated name (e.g. "Levamio Barrierefrei-Check"). This policy applies to all language versions.

1. Controller

NEXTLEVEL CORPORATE SERVICE PROVIDER - FZCO, Building A1, IFZA Business Park, Dubai Digital Park, Dubai Silicon Oasis, Dubai, United Arab Emirates (DIEZ License No. 67837), represented by Tassilo Peter Seitz. Levamio is an offering of NEXTLEVEL CORPORATE SERVICE PROVIDER - FZCO ("we", "us").
Privacy contact: [email protected] (general support: [email protected])

EU representative (Art. 27 GDPR): We are not established in the EU. You can always contact us directly with any data protection matter.
Data protection officer: none appointed at present.

2. Who this policy applies to

"Levamio Accessibility Check" (the "app") is an embedded app for merchants on Shopify. It automatically checks product images and publicly accessible pages of your shop for common barriers based on WCAG 2.2 criteria, shows a score with notes and instructions, offers a self-assessment on the European Accessibility Act (EAA) and a generator for a draft accessibility statement. This policy addresses merchants and their staff who use the app.

3. Our role – and why the app processes no data of your customers

Merchant data: For the data we process about your shop and your use of the app in order to provide the app (section 4), we act as controller (Art. 4(7) GDPR).

Your end customers' data: The app is designed not to process any data of your customers:

It does not request customer or order permissions (no read_customers, no read_orders) and does not request access to Shopify "protected customer data".
It reads products and product images (read_products permission) and fetches publicly accessible pages of your shop (home page, one collection page, one product page, cart – without any customer login, with an empty cart). It does not fetch the checkout.
We therefore answer the Shopify privacy webhooks customers/data_request and customers/redact without returning or deleting data (section 8).

In our assessment a data processing agreement for end-customer data is therefore not required. Where your shop content exceptionally contains personal data (e.g. people in product photos, names in product titles, your contact details on shop pages or in the accessibility statement), we process it only to run the feature you use. To that extent we act on your instructions; our data processing agreement under Art. 28 GDPR applies. It is deemed agreed upon installation of the app without any separate request and is available at https://levamio.com/apps/shopify-barrierefrei/avv-en/.

4. What we process, why, and on what legal basis

Purpose	Data	Legal basis
Installation, authentication, access to your shop	Shop domain (myshopify.com), access token (expiring offline token and refresh token), granted scopes, installation time	Art. 6(1)(b) GDPR (contract of use)
Audit run (score, findings, history)	Shop details (name, primary domain, plan), products (ID, title, handle, status) and product images (ID, URL, alt text); result with score and findings, including short HTML snippets of affected elements (e.g. `<img src="…">`) and colour values; time, trigger (manual, monthly, installation); progress of a running audit in a job table	Art. 6(1)(b) GDPR
Storefront fetch	Public HTML of the pages listed above and the stylesheets (CSS) of your theme linked in them; for password-protected shops the storefront password you enter (stored encrypted with AES-256-GCM)	Art. 6(1)(b) GDPR
AI alt-text suggestions (only when you click)	Image URL (Shopify CDN) and product title, language; suggestion, status (pending, applied, rejected); counters for quota and hourly limit	Art. 6(1)(b) GDPR
EAA self-assessment	Your answers (company size in bands, B2C yes/no, product groups, target markets)	Art. 6(1)(b) GDPR
Accessibility statement (draft, Pro)	Details you enter: company name, address, contact email, phone, shop URL, description, measures, known limitations, authority, date, language	Art. 6(1)(b) GDPR
Plan and billing	Name of the active plan (Free/Pro), subscription status from Shopify; no payment data – billing is handled by Shopify	Art. 6(1)(b) GDPR
Operation, security, debugging	Technical logs in Cloudflare Workers Logs (time, shop domain, webhook topic, error codes, reports of scheduled runs), request metadata including IP addresses when our servers are called	Art. 6(1)(f) GDPR (secure operation)
Support	Your message, email address, shop domain	Art. 6(1)(b) GDPR, otherwise (f) (our legitimate interest in answering enquiries)

What the app does not process: customers, orders, carts with content, payment data, the checkout, theme files via the Admin API (no theme access), names or email addresses of your staff (the app does not use online tokens carrying user details).

What the app writes to your shop: Only – with the additional write_files and write_products permissions, which are requested only on the alt-text page, and after your approval in each individual case – the alt attribute of product images. The app does not change theme code, does not inject any overlay or script into your shop and does not change titles, prices or texts. The app does not publish the accessibility statement; you copy the text yourself.

We do not make automated individual decisions under Art. 22 GDPR. We do not sell data or use it for advertising.

Obligation to provide data: You are not obliged to provide data to us. Without the permissions granted on installation, however, the app cannot be used.

5. Storefront fetch

For the audit, our server fetches the home page, one collection page, one product page and the cart of your shop, as well as the stylesheets linked in them, as a browser without JavaScript would. We load stylesheets only from your shop domains and from cdn.shopify.com. The fetch is identified by its own identifier ("user agent"). We do not store the fetched content in full, only the audit result with counts and at most a few short snippets of affected elements. If your shop is password-protected (e.g. a development store), you can enter the storefront password in the settings; it is stored encrypted, used only for this fetch and deleted with your other data.

6. AI alt-text suggestions (Anthropic)

Only when you request a suggestion in "Alt texts" does our server send the product image URL (Shopify CDN), the product title and the desired language to Anthropic (Anthropic PBC, USA, provider of the "Claude" language model). Anthropic retrieves the image via the URL and returns a suggested text. We send no customer data and no other shop data. Our server loads the image URL and title itself via the Shopify API and checks that the image belongs to your shop.

The suggestion is saved as a draft and applied in Shopify only after you review and approve it. It is generated automatically and may be inaccurate.
Anthropic processes the data as our processor under its commercial terms and Data Processing Addendum. According to Anthropic's current information, API data is not used for training and is usually deleted within 30 days; longer only in exceptional cases (e.g. content flagged for usage-policy violations or legal obligations).
Transfers outside the EU: see section 10.
Please do not request suggestions for images showing identifiable people unless you have a legal basis to do so.

7. Accessibility statement (draft)

We store the details you enter in the generator so that you can edit the draft later. We display the generated text only to you; you publish it yourself. If the statement contains personal data (e.g. your name as a sole trader or a personal email address), you are responsible for publishing it.

8. Shopify privacy webhooks and uninstalling

Event	What we do
`customers/data_request` (an end customer's access request via Shopify)	We hold no customer data; nothing to provide. We log only receipt, topic and shop domain.
`customers/redact` (an end customer's erasure request)	As above: nothing to delete; receipt is logged.
`app/uninstalled` (you uninstall the app)	We immediately delete access tokens (sessions), cancel open audit runs and mark the shop as uninstalled.
`shop/redact` (sent by Shopify 48 hours after uninstalling)	We delete all stored data of your shop: settings, encrypted storefront password, EAA answers, accessibility statement details, audit runs and history, alt-text suggestions and sessions.

All privacy webhooks are verified using Shopify's HMAC signature. Alt texts you applied via the app remain in Shopify as part of your product data.

9. Storage location and retention

Location: database at Supabase in the EU region Frankfurt (AWS eu-central-1). The app itself runs as a Cloudflare Worker on Cloudflare's global network; with "Smart Placement" it preferably runs close to the database. The database connection uses Cloudflare Hyperdrive (connection pooling, query caching disabled). The Worker's execution location is not limited to the EU. Your shop content itself stays with Shopify.

Retention:

All shop data in the app: while the app is installed; after uninstalling until the shop/redact webhook (usually 48 hours), then complete deletion. If shop/redact does not arrive, we usually delete all data of an uninstalled shop completely 7 days after uninstallation.
Audit history (score history): audit runs older than 24 months are usually deleted automatically; at the latest on shop/redact.
Alt-text suggestions: until applied or rejected, then usually no longer than 90 days; at the latest on shop/redact.
Completed audit jobs including error messages: usually no longer than 30 days after completion.
Expired login sessions (online sessions): usually 1 day after expiry; permanent access tokens are deleted on uninstallation.
EAA answers and accessibility statement details: until you change them or uninstall the app (then on shop/redact).
Server logs: usually no longer than 30 days.
Support requests: up to 3 years after closure.
At Anthropic: according to Anthropic's current information usually no longer than 30 days, longer in exceptional cases (section 6).

10. Recipients and international transfers

Service	Purpose	Location / processing	Safeguard
Shopify	Platform, authentication, webhooks, billing of app plans	Shopify International Ltd., Ireland; Shopify Inc., Canada	independent controller for your Shopify account and billing; Canada: adequacy decision
Supabase	Database	Supabase, Inc., USA; data in EU region Frankfurt	DPA; SCCs or DPF where applicable; copy on request
Cloudflare	Running the app (Workers), database connection (Hyperdrive), scheduled runs (cron), logs, network	Cloudflare, Inc., USA; global network	DPA (Cloudflare DPA); SCCs or DPF where applicable; copy on request
Anthropic	AI alt-text suggestions (only on click)	Anthropic PBC, USA	DPA; SCCs or DPF where applicable; copy on request

Transfers: Anthropic processes data in the USA. For the USA, the adequacy decision on the EU-US Data Privacy Framework (DPF) applies; it covers only certified recipients. If a recipient is not certified, we rely on the European Commission's Standard Contractual Clauses (Art. 46(2)(c) GDPR) in its DPA. On request we tell you which safeguard applies.

United Arab Emirates: We, as controller, are established in the UAE; there is no adequacy decision for the UAE. We apply the GDPR to the extent it applies to our services and access EU-stored data only via encrypted, authenticated connections.

11. Security

HTTPS in transit, AES-256-GCM encryption of the storefront password, signature verification of all webhooks, per-shop data separation, access only via Shopify session tokens, storefront fetches only to your shop domains (and cdn.shopify.com for stylesheets) with protection against redirects to third-party or internal addresses, scheduled jobs as Worker cron triggers (manual calls only with a secret key), database access only via Hyperdrive with row level security enabled, minimal permissions (write permissions requested only when needed).

12. Your rights

Under the GDPR you have the right of access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and to object to processing based on legitimate interests (Art. 21). The quickest way to delete all data is to uninstall the app (section 8). Contact [email protected]; we usually respond within one month. You may lodge a complaint with a data protection supervisory authority, in particular in the EU/EEA member state of your habitual residence, place of work or the alleged infringement; in Switzerland with the Federal Data Protection and Information Commissioner (FDPIC).

Right to object (Art. 21 GDPR): Where we process data on the basis of legitimate interests (Art. 6(1)(f) GDPR, e.g. operation and security), you may object at any time on grounds relating to your particular situation. We will then stop processing unless we demonstrate compelling legitimate grounds which override your interests, rights and freedoms, or the processing serves the establishment, exercise or defence of legal claims. An informal message to [email protected] is sufficient.

13. Changes

We update this policy when features, service providers or the law change. We inform you of material changes in the app. The current version is at https://levamio.com/apps/shopify-barrierefrei/datenschutz-en/.

As of: 21 October 2026