Privacy Policy
Roles under GDPR
Skipaki is the controller for operator account data — your business name, contact details, billing, telemetry on how the portal is used.
Skipaki is the processor for your customers' data — names, phones, addresses, orders, invoices that your operators enter into the portal. You are the controller; we process strictly on your instructions and under a Data Processing Agreement (see DPA, coming soon).
What we collect from operators
- Account: business name, legal name, VAT number, base city, contact phone and email
- Billing: bank IBAN, invoice prefix, default VAT rate, supplier address
- Team: invited members' emails and roles
- Authentication: email, password hash, session tokens (handled by Supabase)
- Usage: timestamps of which pages you visit inside the portal, errors, performance traces
What we process on behalf of operators
- Operator's customers: name, phone, email, address, notes, order history
- Orders: address (with lat/lng), container size, waste type, dates, prices, payment terms
- Invoices: customer name and address frozen at issue time, line items, totals
- Audit log: every state change with actor name, action, timestamp (Art. 30 record)
Legal basis (GDPR Art. 6)
- Performance of contract — your subscription agreement with Skipaki
- Legal obligation — invoice retention under Cyprus tax law
- Legitimate interest — service security, fraud prevention, product analytics
Sub-processors
The full, current list with locations and safeguards is at /promo/legal/sub-processors. The main ones: Supabase (EU), Vercel (EU), Google Maps (US, SCCs), OpenAI for AI freeform parsing (US, SCCs + zero-retention), MailerSend (EU).
Cross-border transfers
Operator and customer data primarily lives in Dublin (eu-west-1). Two flows leave the EU under Standard Contractual Clauses:
- Google Maps — customer addresses sent to geocode and route. Google operates under SCCs and the EU-US Data Privacy Framework.
- OpenAI — freeform job notes sent for parsing into structured fields. Zero-retention enabled at the API layer; OpenAI does not log the prompt/response.
Retention
- Operator accounts: while the subscription is active + 90 days
- Customer records: while the operator's account exists; soft-deleted records hard-deleted after 90 days
- Invoices: 7 years (Cyprus tax law) — personal details may be anonymised after that period on request
- Audit log: while the operator's account exists
- Authentication sessions: refresh tokens valid 1 year, rotated continuously
Your rights (Art. 15-22)
- Access — operators can export their full data set via the export tool at
/pro/reports/export(a dedicated DSAR export is on the roadmap) - Rectify — edit any record directly in the portal
- Erasure — request account deletion via privacy@skipaki.com
- Restrict / object — email us and we'll suspend processing while we review
- Portability — JSON/CSV export of operator and customer records on request
We respond within one calendar month.
Security
- Row-Level Security on every Postgres table — each operator sees only their own data
- HTTPS only, HSTS preload, modern security headers
- Auth tokens scoped to
*.skipaki.comwith same-site lax cookies - Append-only audit log of every state change
Breach notification
If we detect unauthorised access to operator or customer data we notify affected operators within 24 hours and the Cyprus OCDPC within 72 hours per Art. 33.
Complaints
You can complain to the Cyprus Commissioner for Personal Data Protection at dataprotection.gov.cy.
Contact
Privacy questions: privacy@skipaki.com. General support: hello@skipaki.com.
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