WithdrawKit: Privacy Policy & Data Processing Terms

Last updated: 23 July 2026 · Contact: support@widthkey.store

WithdrawKit ("the app") helps Shopify merchants comply with the EU right of withdrawal (Directive (EU) 2023/2673, Article 11a of Directive 2011/83/EU). This page describes exactly what personal data the app processes, why, and for how long. The app is operated with EU-hosted infrastructure.

What we process, and why

The app processes the minimum personal data required to operate a withdrawal function on the merchant's store:

• Data entered by the customer on the withdrawal form: name, email address, order number, optionally selected items and a voluntary note.
• Order data read from Shopify on demand to verify the request: order number, order email, line items, fulfillment and payment state. Orders are never synced or copied in bulk.
• Compliance records: the withdrawal statement, its submission timestamp, the confirmation emails sent (stored verbatim as the legally required durable-medium evidence), and a tamper-evident audit trail.
• Technical data: IP address and browser user agent of a submission, stored as evidence against abuse.

Purpose is strictly limited to receiving, verifying, recording, and processing withdrawal requests, including the legally required confirmations. No analytics on personal data, no profiling, no marketing, and no sale or sharing of personal data, ever.

Legal basis

Processing is performed on behalf of the merchant (the controller) to fulfil their legal obligation under EU consumer law and to execute the customer's own withdrawal request. WithdrawKit acts as a processor.

Where data lives

• Application and database: Fly.io, Amsterdam (EU region). Traffic is TLS-encrypted; internal networking is WireGuard-encrypted; storage volumes are encrypted at rest.
• Transactional email: Brevo (EU provider). Emails are sent from the merchant's configured sender identity.

Retention

• Withdrawal records are kept while the app is installed, as the merchant's legal evidence.
• On uninstall, all shop data is erased after a 48-hour grace window.
• Shopify GDPR webhooks are honored: customer redaction requests wipe personal data from records and tombstone the related audit entries; shop redaction erases everything.

Customer rights

Data subject requests (access, erasure) should be directed to the merchant, who controls the data. The app fulfils them through Shopify's standard GDPR webhooks, including data export on request and redaction.

Subprocessors

• Fly.io (hosting, EU region)
• Brevo (transactional email, EU)
• Shopify (platform APIs)

Data processing terms

By installing the app, the merchant instructs WithdrawKit to process the data described above solely for the purposes described above. WithdrawKit processes data only on these documented instructions, applies the technical and organisational measures described on this page, engages only the listed subprocessors, assists the merchant with data subject requests via the mechanisms above, and deletes data per the retention terms. Questions and requests: support@widthkey.store.