Version 1.1 · 15/10/2026
1Controller
The data controller is CodeMerry Srls, VAT 00000000, Via Elios Mauro 29, email https://my.codemerry.com/contact.php?product=vouchler, PEC codemerry@pec.it. No data protection officer (DPO) has been appointed, as the legal conditions do not apply; requests must be addressed to the contacts indicated.
2What data we process
Customer data: name, buyer type (individual or company), company, VAT number, tax code or the country's personal code, SDI recipient code or PEC, address, email, phone, order and payment references (PayPal or Stripe transaction id; we never see card data or bank details, collected directly by the payment circuit) and the data the circuit returns to us about the payment: identifier and email of the PayPal or Stripe account used to pay, name and country of the payer as recorded by the circuit, outcome, date, fees and net amount of the transaction, identifier and dates of any subscription. We use them to reconcile receipts, issue receipts and tax documents and defend ourselves in payment disputes; they stay with the order for the tax period. These data are encrypted at rest. Account data: username, encrypted email, password hash and, for security purposes, a log of sign-ins and account actions with date and time, IP address and technical information about the browser and device (user agent). Service data: installation settings, voucher codes, activity log, support tickets and commercial enquiries (with any attachments). Relationship data: our staff's internal notes and reminders about the customer or the enquiry (encrypted, never shared with the customer, never included in exports), offers proposed and their outcome. Technical error log: when a page stops because of a software error we record page, date and time, account, IP address, browser and incident code. Email delivery: bounce and complaint notifications and a list of addresses we no longer write to. Log of refused or not-found requests: to detect scans and attempts to reach restricted files we record the requested path, date and time, IP address and browser, for 30 days. Attachments: pictures and PDFs uploaded in tickets and requests (up to 3 files per message, 5 MB each) are kept with the conversation in a folder not reachable from the web, without changes to the original content and metadata; they are visible only to the Customer, through the personal link, and to our staff, and are never sent to the AI provider, which receives only the text of the messages with contact details, IBANs and fiscal codes masked. Platform data: technical identifiers of installations and licences, the licence documents exchanged between the central seat and the software and the log of the calls between the systems (date and time, event type, outcome, identifiers; never the content of vouchers nor guest data). VAT number check: for customers holding a VAT number of another EU State we send country and number to the European Commission's VIES system and keep the outcome with the order. Bin: for 30 days after the deletion of an account we keep, encrypted, what is needed to restore it (installations, roles, expiries, renewal state), then delete it for good. Beta access requests: first and last name, email, type and name of the venue, optional note and consent to news, provided with the request form.
3Guest data
Through the Service the Customer manages WiFi vouchers. The Service can show, from the Customer's UniFi® controller, technical data of connected devices (MAC address, hostname, traffic). For these data the Customer is the controller and the Provider acts as processor on the Customer's instructions, under the license terms. The Service does not record or keep the sites visited by guests.
4Purposes and legal bases
Performing the contract (license, activation, support, renewals); legal obligations (accounting, tax); legitimate interest in security (login protection, fraud prevention, logs). No marketing profiling, no sale of data, no automated decision-making producing legal effects on data subjects. Legitimate interest in managing the commercial relationship: internal notes and priority or potential ratings of a request, used only to organise our staff's work, with no legal effect on the data subject. Legitimate interest in defending our rights (art. 6(1)(f) GDPR) in case of payment disputes, chargebacks or litigation: use of the Service's records and their disclosure to the payment circuit and to our advisers. Handling beta access requests and invitations (pre-contractual measures at the data subject's request). Legitimate interest in proving undertakings: date, time and IP address with which a person accepts the conditions, the confidentiality undertakings of the beta or gives a consent.
5Retention
Contract and order data: for the time required by tax law (normally 10 years). Installation data: for the licence term and up to 12 months after expiry to allow reactivation, then deleted; earlier deletion on request to https://my.codemerry.com/contact.php?product=vouchler. Security logs: 12 months. Support tickets and commercial enquiries: 24 months. Internal notes and reminders: for the duration of the relationship and up to 24 months after its end. Technical error log: 90 days. List of bounced or complaining addresses: until the person asks to be readmitted, and in any case reviewed every 24 months. Shop statistics: 12 months. Encrypted backups follow an automatic rotation and are deleted within 30 days of the deletion of the source data. Attachments follow the retention of the ticket or request they belong to and can be deleted earlier on request. Log of newsletter and communication sends (recipient, date, outcome, unsubscription): 24 months, as evidence of consent and of its withdrawal. WiFi guest sessions of the properties (code, device, times, traffic — never the sites visited): processed on behalf of the property, which is the controller and picks the retention from its panel (default 12 months, between 30 days and 24 months); then deleted automatically. Files and records concerning a payment dispute: for the duration of the dispute and of the subsequent appeal and legal-protection periods, then deleted. Events and calls between the central seat and the software: event content 30 days, identifiers and call log 12 months, anti-replay codes 10 minutes; licence documents of a deleted installation: 12 months. Accounts in the bin: 30 days from deletion, then permanent deletion. Outcome of the VIES check: with the order, for the tax period. Beta access requests not followed by an activation: until the end of the beta programme and in any case no longer than 12 months. History of the controller changes of each property (technical fingerprints of the consoles, reasons, outcomes, data read from the consoles as counts and yes/no): without a time limit, to recognise a console already used by another property and to prevent the use of one licence on several properties (legitimate interest); when the account is deleted the row stays the property's, without the person and without the texts he wrote.
6Recipients and processors
Hosting provider of our servers (EU). PayPal and Stripe (payments, each with its own notice). Amazon Web Services (Amazon SES, EU Stockholm region) and other mail providers for service emails and newsletters: from them we receive only bounce and complaint notifications. Ubiquiti® cloud services used to reach the Customer's controller. While filling in the address, the text typed in the address field may be sent from our server to the Photon geocoding service (OpenStreetMap data) to suggest completions: the request leaves from our server, without the visitor's IP address, cookies or other data. Optionally an AI provider processes the text of support tickets and commercial enquiry messages, for example to translate them into the Customer's or our staff's language, recognise their language or propose a draft reply to our staff, and receives aggregate, non-identifying data (counts, income) for internal management notes; it never receives guest data. When electronic invoicing is active, the buyer's tax data (name or company name, address, VAT or tax code, recipient code or PEC, amounts) are transmitted to our e-invoicing provider and, through it, to the Italian Revenue Agency's exchange system, as required by law. Our authorised staff access data with personal credentials and with permissions limited to the functions their role requires; every relevant action is logged. The timestamp authority that may be used for signed documents receives only the cryptographic fingerprint of the file, never its content nor personal data. In case of a payment dispute, PayPal or Stripe (and, through them, the customer's bank or card issuer) receive the records needed for the defence: order data, acceptance of the terms with date, time, IP address and browser, activation, logins and activity, receipts, correspondence. The AI provider, when enabled, may receive a summary of the case to propose answer drafts to our staff, which are always reviewed and sent by a person. Fatture in Cloud (TeamSystem group) is our electronic invoicing provider: it receives the buyer's tax data, the description and the amounts to issue invoices and credit notes and transmit them to the exchange system (SdI). European Commission (VIES system): receives country and VAT number for the check. Stripe also collects the SEPA direct debit mandate and the account details for the debits: we never see the full IBAN. The systems of the Provider's platform (central seat and individual software) exchange the data described in the section "What data we process": they are all systems of the Controller, hosted in the European Union. AI providers are used through professional interfaces whose terms exclude the use of the submitted data to train the models.
7Transfers outside the EU
Some providers (PayPal, Stripe, Ubiquiti®, AI providers, Google) may process data outside the EU under standard contractual clauses or adequacy decisions. For users in the United Kingdom and Switzerland, references to the GDPR include the UK GDPR and the Swiss FADP respectively, and transfers rest on the equivalent instruments (adequacy decisions, IDTA/standard clauses).
8Security
Encrypted transport (HTTPS), passwords hashed with Argon2id, secrets and personal data encrypted at rest with per-installation keys, two-step verification by email, access logs, regular backups. Public forms are protected by anti-abuse checks without third-party captchas (hidden field, time to fill, rate limits per IP address). The platform's systems authenticate each other with dedicated keys, a signature on every request, anti-replay codes and periodic key rotation; API keys and payment-circuit secrets are kept encrypted in a vault bound to their context of use; automatic security alerts (anomalous logins, refused requests, anomalies in payments and refunds) reach the owner; texts editable from the panel are stripped of code before publication; every page is protected by a content security policy (CSP) that admits only the Service's own scripts and, on the payment pages, those of the PayPal and Stripe circuits.
9Your rights
Access, rectification, erasure, restriction, portability, objection, and complaint to the supervisory authority. Write to https://my.codemerry.com/contact.php?product=vouchler, stating the name and email address of the account: we may ask for identity verification before acting. We answer within one month, extendable by two months in complex cases, with notice. Manifestly unfounded or excessive requests may be refused or subject to a reasonable fee, as provided by Art. 12 GDPR. For data subjects in Italy the supervisory authority is the Garante per la protezione dei dati personali (www.garanteprivacy.it); in the other Union countries, the authority of your State of residence or work.
10Updates
This policy may be updated; the version in force is shown at the top (version 1.1).
11Newsletter and communications
The newsletter is sent only with consent, with double opt-in; every message contains a one-click unsubscribe link. Service emails (credentials, receipts, expiry notices, security) are necessary for the performance of the contract and do not require consent. Based on the existing relationship, we may also send Customers occasional communications about renewals and offers for services similar to those already purchased: every message contains a one-click opt-out link. Newsletter pictures are hosted on our own servers: we use no tracking pixels and do not measure opens or clicks of individual recipients.
12Data breaches
In case of a personal data breach the Provider applies the measures required by the GDPR, including, where applicable, notification to the supervisory authority within 72 hours and communication to the data subjects.
13Minors
The Service is intended for businesses and adults. We do not knowingly collect data of minors; if you believe this has happened, write to https://my.codemerry.com/contact.php?product=vouchler and we will delete the data.
14Storefront statistics
On public pages we keep first-party statistics without cookies and without storing IP addresses (visitors are counted with a non-reversible daily fingerprint). Only if you accept cookies from the banner, an optional cookie (uv_vid, 12 months) lets us recognise returning visitors; refusing it changes nothing in your use of the site. The public demo (demo.php) opens a demonstration panel on a fictitious hotel: what the visitor creates or changes stays in his session and his own space, is not visible to other visitors and is deleted on exit or after two hours; the demo log keeps only the entry and the refused actions, with a shortened IP address, wiped every six hours; no email is sent from the demo.
15Users in the United States
We do not sell or share personal information for advertising purposes under any definition, including those of California law (CCPA/CPRA). We honour access, deletion and correction rights for all users, wherever they reside, by writing to https://my.codemerry.com/contact.php?product=vouchler. California residents may also contact the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs.
16Updates about our services
If you are our customer, we may email you news and offers about our services similar to those you purchased, as allowed by Article 130(4) of the Italian Privacy Code: you can refuse at purchase time and unsubscribe at any moment, free and in one click, from the link in every message. For the free trial and information requests we ask for explicit, optional consent instead. Unsubscribing never affects service messages (receipts, expiry notices, security).
17Reserved area, devices and preferences
In the «My Codemerry» reserved area we process: (a) the data of the person who manages the account (first name, last name, email, optional phone, language) to identify and contact him and to name documents — legal basis: the contract; (b) the sessions register (an encrypted fingerprint of the session, the browser, the IP address, date and time of opening and of last use) for the security of the account and to let him close connected devices — legal basis: the legitimate interest in security and the contract; retention: sixty days from the last use; (c) the register of preferences and consents (what was chosen, when, from which address, under which version of the terms) to prove the will expressed — legal basis: legal obligation (art. 7 GDPR); retention: for the relationship and as long as needed to assert or defend a right; (d) the attachments of support requests, kept with the request; (e) the billing profiles, kept with the fiscal documents for ten years. The Customer may export all his data and close the account from the reserved area at any time, even without having accepted new terms.
18WiFi health, AI analysis and device data
For the “WiFi health” page the software reads from the venue’s network controller the technical data of the access points (channel, width, utilisation, power), of the connected devices (signal strength, band, retransmissions, experience index, device vendor) and of the neighbouring networks (channel, strength). The venue owner processes these data to run and improve his own network (art. 6.1.f GDPR, legitimate interest); the panel shows them in aggregate form and keeps them no longer than ten minutes. The “full analysis with advice” sends to an artificial-intelligence provider, through Codemerry, ONLY aggregates (devices per access point, signal distribution, channels and neighbouring networks, the rhythm of the sessions) and the venue’s name: no MAC address, device name or data referable to a person leaves the panel. The report obtained stays in the venue’s panel for one day. The detail of a voucher in use may show the manager, when the controller provides it, the vendor and name of the device, its internal IP address and the access point: information the manager processes as part of running his own network and that is not shared with Codemerry.
19Withdrawal requests and analysis supporting the decision
When the Customer sends a withdrawal request from the reserved area, we process what they write, the attachments and the data of their contract (licences, orders and refunds, use of the service, support requests, notices received) to examine it and answer; the legal basis is the performance of the contract and compliance with legal obligations. To help the person who decides, an artificial intelligence system of a third-party provider may prepare an analysis of the facts and of the terms: from the records we send it no addresses, IP addresses or payment data. The analysis is not a decision and is not communicated to the Customer: the decision is always taken by a person, so there is no decision based solely on automated processing within the meaning of Art. 22 GDPR. The request, the analysis and the decision are kept with the contract documents for the period required by tax law and for the defence of rights in court. The Customer may ask which facts were considered and contest the decision by writing from the contact form.
These texts are provided by the seller. Keep a copy for your records.