Privacy Policy
1. Who we are
[COMPANY LEGAL NAME, e.g. Example Software Ltd] (CRO [CRO COMPANY NUMBER]), [REGISTERED OFFICE ADDRESS, IRELAND], operates PayGap Pro. For personal data about website visitors and purchasers, we are the controller. Contact us about data protection at [PRIVACY / DATA PROTECTION EMAIL]. [CONFIRM WHETHER A DATA PROTECTION OFFICER IS REQUIRED; likely not for a business of this size and activity.]
2. Payroll files you upload: we are your processor
When an employer uploads a payroll file, the employer is the controller of its employees' data and we process it on the employer's behalf under our Data Processing Agreement. How it works:
- Processed in memory, not stored. Payroll files are read in server memory only for as long as it takes to calculate your figures and build your PDF. We do not write them to disk or to a database, and we do not keep copies after the request ends.
- To let you edit your statement and then download the PDF without us storing the file, the results page sends the file back to your browser in a hidden form field. It's sent to us again only when you request the PDF, and is again processed in memory only.
- We configure our servers and hosting so request bodies (which contain the payroll file) are not logged.
- Payroll data is never sent to Stripe or any other third party, and is not used for analytics, training or any other purpose.
- We recommend uploading employee IDs rather than names. The template asks for no names.
Employees with questions about their data should contact their employer, which decides how it is used.
3. Personal data we control
| Data | Purpose | Legal basis (GDPR) | Retention |
|---|---|---|---|
| Purchaser name, email, billing address, VAT number (collected by Stripe Checkout and shared with us) | Taking payment, issuing invoices/receipts, customer support | Contract (Art. 6(1)(b)); legal obligation for tax records (Art. 6(1)(c)) | [6 years from the end of the relevant tax year: CONFIRM WITH ACCOUNTANT] |
| Purchase record: Stripe session ID, tier, amount, currency, timestamps, a hash of your download token and usage count | Confirming payment, unlocking your report, preventing token reuse and fraud | Contract (Art. 6(1)(b)); legitimate interests in preventing misuse (Art. 6(1)(f)) | [6 years: CONFIRM] |
| Stripe webhook event IDs | Processing each payment event once | Legitimate interests (Art. 6(1)(f)) | [90 days: TO IMPLEMENT pruning] |
| Technical data: IP address, browser user agent, request time and URL in server logs (no request bodies) | Security, troubleshooting, abuse prevention | Legitimate interests (Art. 6(1)(f)) | [30 days: CONFIRM] |
| Emails you send us | Answering your questions | Legitimate interests (Art. 6(1)(f)) or contract | [2 years: CONFIRM] |
We never receive your full card details; Stripe handles them.
4. Cookies
We use one cookie, pgp_token, which holds your download token after purchase so your browser can unlock the report you paid for. It is strictly necessary to provide the service you asked for, so no consent banner is used. It expires when the token expires. We use no analytics or advertising cookies. [UPDATE IF ANALYTICS ARE ADDED: consent would then be needed.]
5. Who we share data with
- Stripe (Stripe Payments Europe, Limited, Ireland) processes payments on our behalf. For some activities, such as fraud prevention and meeting its own legal obligations, Stripe acts as an independent controller under its own privacy policy (stripe.com/privacy).
- Hosting: Render Services, Inc., which hosts the application in the EU (Frankfurt, Germany (EU)).
- [EMAIL PROVIDER, ACCOUNTANT, if used].
- Authorities, where we are legally required to share data.
6. Where data is processed
The application and its database are hosted in the European Union. Stripe may transfer data outside the EEA under its own safeguards, such as Standard Contractual Clauses or the EU–US Data Privacy Framework; see Stripe's privacy policy. [CONFIRM ALL PROVIDERS AND TRANSFER MECHANISMS BEFORE LAUNCH.]
7. Security
Encryption in transit (HTTPS), no storage of payroll files, download tokens stored only as hashes, least-privilege access to production systems, and regular dependency updates.
8. Your rights
Under the GDPR you have the right to access, rectify and erase your personal data, to restrict or object to processing, and to data portability, subject to legal limits. Contact [PRIVACY / DATA PROTECTION EMAIL]. We reply within one month. You may also complain to the Data Protection Commission (Ireland), www.dataprotection.ie, or to the supervisory authority where you live or work.
9. Changes
We will post any changes here and update the date below. Material changes will be highlighted on the website.
Version draft-2026-10-04 · last updated 4 October 2026