Privacy Policy

eMatjarak is a software platform operated by [[ TODO: legal review — company legal name / registration number / jurisdiction / registered address ]].

This policy covers the platform's own website, the merchant dashboard, and the storefronts we host for merchants.

It does not replace the privacy notice of an individual store. Each merchant publishes their own.

“Personal data”: any information that identifies a person or can be linked to one — a name, a phone number, an e-mail address, a delivery address, an order history, an IP address.

“Merchant”: the person or business that opens or runs a store on the platform.

“Shopper” or “customer”: a person who deals with a store run by a merchant on the platform.

“Store”: an individual shop on the platform, with its own catalog, orders and customers.

“Processing”: anything done with personal data — collecting it, storing it, using it, sharing it, deleting it.

For merchant accounts — the people who open and run a store — eMatjarak decides how the data is used, and this policy applies directly.

For shoppers of a store — the people who buy from a merchant — the merchant decides how the data is used. We hold and process that data on the merchant's behalf so their store can work, acting on the merchant's instructions and on our own security and legal obligations, not on commercial purposes of our own.

The merchant's own privacy notice governs how they use it, and a request about a specific store should go to that merchant first.

Each store's data is isolated from every other store's data on the platform. [[ TODO: legal review — the controller / processor terminology of the applicable law, and whether a separate data-processing agreement with merchants is required ]]

Merchant account data: name, e-mail address, phone number, a hashed password, staff accounts and their roles, and the settings, branding and content of the store.

Billing data: plan, billing cycle, invoices, transfer references, coupons and the commission recorded per order. We do not store card numbers.

Shopper data held for merchants: name, e-mail address, phone number, delivery addresses, order and return history, wishlists, reviews and questions, newsletter subscriptions.

Marketing and attribution data: the campaign, source and click identifiers that brought a visitor to a store, where the merchant has switched those features on.

Technical data: IP address, browser and device information, request timestamps, error logs and service metrics.

Messages: support tickets, contact-form messages and the notifications we send on a merchant's behalf.

To create and run stores and process their orders.

To send transactional messages — order confirmations, shipping updates, one-time verification codes, password resets.

To bill subscriptions and record commission.

To prevent fraud and abuse and to keep the platform secure.

To provide support and to answer merchant questions.

To understand how the platform is used, in aggregate, so we can improve it.

Because it is needed to provide the service that was asked for and to perform the agreement between us — creating stores, processing their orders, billing, and support.

Because the law requires it — accounting and tax records, and responding to a lawful request from an authority.

Because we have a legitimate interest in keeping the platform working, secure and free of fraud and abuse, and in understanding in aggregate how it is used so we can improve it.

Because consent was given, where consent is what applies — optional analytics and marketing messages. Consent can be withdrawn at any time. [[ TODO: legal review — the legal bases recognised by the applicable law and how they must be described ]]

When a shopper buys from a store, their data is held for that merchant. We use it to run the store, to send the messages the order needs, to keep the platform secure and to meet our own legal obligations. We do not use one merchant's customer data to market anything of our own, and we never share it with another merchant.

The merchant is responsible for having the privacy notice and any consent their own law requires for their customers, for the marketing they send them, and for the pixels and integrations they add to their store.

A merchant who exports customer records is responsible for those records from that point on.

We share data only with the providers needed to run the service, and only with what they need:

hosting and database infrastructure;

e-mail delivery, and SMS or WhatsApp providers where those channels are enabled;

payment and wallet providers, for the reference of a transfer;

couriers, where a merchant hands an order over for delivery — the address and contact details the delivery needs;

an AI provider, when a merchant uses the AI writing assistant, for the content of that request;

marketing and analytics services, only where a merchant or the operator has switched them on.

We do not sell personal data, and we do not share one merchant's data with another. We may disclose data where the law requires it. [[ TODO: legal review — hosting locations, cross-border transfer basis and the list of named sub-processors ]]

Most orders on the platform are cash on delivery or a wallet transfer. In both cases the money moves between the customer and the merchant, not through us.

For a wallet payment — Sham Cash, Syriatel Cash, MTN Cash — we record what the customer enters, which is the reference of their transfer and the wallet it was sent from, so the merchant can verify it. We do not connect to a wallet account and we do not see a balance or a transaction history.

We do not receive, store or process bank card numbers, card security codes or wallet passwords, and we never ask for them.

Cash on delivery involves no payment credentials at all: we record that the order is to be paid on delivery and, where the merchant uses it, a one-time code sent to the customer's phone to confirm the order.

When a merchant uses the AI writing assistant, the product information in that request is sent to our AI provider to generate the description, and the result is written back into the merchant's catalog.

We record that a generation happened and how many tokens it used, so it can be metered against the plan. We do not keep a separate copy of the prompt or the answer.

The assistant is meant for product information, and merchants are asked not to put customer data into a prompt. [[ TODO: legal review — the AI provider to be named, where it processes the request, its retention period, and confirmation that prompts are not used to train models ]]

We do not use personal data to make automated decisions that have a legal or similarly significant effect on anyone.

The platform sets the cookies it needs to keep you signed in, to keep a cart together, to remember your language and currency, and to protect forms. These are essential and cannot be switched off without breaking the service.

A merchant may add their own marketing pixels — Meta, TikTok, Google Analytics, Snapchat — to their own store. They run only on that store, they are the merchant's choice and responsibility, and any consent they need is the merchant's to obtain.

Where a merchant configures a conversions API for Meta, TikTok or Google Analytics, the platform also sends that store's order events to the service from our server. A customer's e-mail address and phone number are hashed before they are sent, never transmitted in readable form.

The platform's own site uses analytics only where the operator has configured it. [[ TODO: legal review — consent requirements for non-essential cookies and pixels, and whether a consent banner is required for visitors ]]

The platform runs on hosted infrastructure, and several of the providers listed above — e-mail, messaging, AI and analytics services — process data outside Syria. Using the platform therefore involves personal data being sent to and stored in other countries.

We choose providers we consider able to protect the data, and we send each of them only what their part of the service needs. [[ TODO: legal review — the countries where data is hosted and processed, the named sub-processors, and the legal basis and safeguards required for cross-border transfer under the applicable law ]]

Account and store data is kept while the store is active.

Order, invoice and commission records are kept after that for accounting and legal reasons.

A store's activity log — who changed what in the dashboard — is kept for 180 days.

Logs and service metrics are kept for a short operational period.

When we no longer have a reason to keep personal data, we delete it or make it anonymous. [[ TODO: legal review — exact retention periods and the statutory bookkeeping minimum ]]

We back up the platform database daily, keep a limited history and hold a copy away from the server.

Deleting something removes it from the live service straight away, but it can survive in a backup until that backup ages out of the rotation, a matter of weeks. Backups exist to restore the service after a failure; we do not use them to bring back data that was deleted on request. [[ TODO: legal review — the maximum period a deleted record may persist in backups, to be stated here as a fixed figure ]]

Passwords are stored hashed and are never kept in readable form. Traffic is encrypted in transit.

Each store is scoped to its own channel, so one merchant cannot read another's catalog, orders or customers.

Access to production data is limited to the people who need it to operate the service. Sensitive endpoints are rate-limited, and changes made in the dashboard are recorded in a per-store activity log.

No system is completely secure, and we do not claim that ours is.

If a security incident affects personal data, we investigate it, act to contain it, and take the steps the applicable law requires. We notify the authorities or the people concerned where notification is legally required, and we tell an affected merchant what we know about an incident that touches their store's data. [[ TODO: legal review — the notification deadline, the authority to be notified, and the threshold at which notification is required under the applicable law ]]

You can ask for a copy of the personal data we hold about you, ask us to correct it, ask us to delete it where we are not required to keep it, ask us to restrict or object to a particular use, and withdraw a consent you gave.

Send the request to the address at the end of this page. We will ask for enough information to be sure who you are — we will not act on a request about someone's data from a person we cannot identify — and we will not ask for more than that takes.

We answer as quickly as we can. We may decline a request in whole or in part where the law requires us to keep the data, where answering it would expose someone else's personal data, or where it is manifestly unfounded or repetitive; we explain why when we do.

Merchants can export their catalog, orders and customer records from the dashboard at any time.

If your request is about data held for a particular store, contact that merchant first; if they do not respond, contact us and we will help. [[ TODO: legal review — the response deadline, which data-protection law applies, and the supervisory authority for complaints ]]

The platform is meant for adults. A merchant account may only be opened by someone legally able to run a business, and the platform is not directed at children.

We do not knowingly collect personal data from a child. Where a merchant's own store collects data from children, that is the merchant's responsibility and the merchant must have whatever consent their law requires.

If you believe a child's personal data has reached us, contact us and we will delete it unless the law requires us to keep it. [[ TODO: legal review — the age of a child under the applicable law, and the parental consent required below it ]]

A merchant can export their catalog, orders and customer records as CSV before closing.

When a store closes, its storefront goes offline and its subdomain is released. The store's data is kept for a period — so it can be restored, so disputes and invoices can be settled, and so we can meet accounting obligations — and is then deleted or made anonymous.

Shopper data held for that store is not handed to another merchant and is not added to any list of ours. [[ TODO: legal review — how long data is kept after closure, and what happens to it if a store is sold or transferred to a new owner ]]

We update this page when our practices change, with a new “last updated” date at the top. Where a change materially affects how personal data is used, we announce it to merchants in the dashboard before it takes effect.