Privacy Policy
Draft notice — advanced draft: this document is product-accurate and reflects the direction agreed ahead of legal review with EY Ventury Avocats. Sections in brackets (company name, registered address, data protection contact) are placeholders to be finalized once the SASU is incorporated. This text has not yet been reviewed by counsel and should not be treated as final or binding until both points are settled.
This Privacy Policy explains what personal data bepleez processes, why, and the rights available to you — whether you're a Merchant using bepleez on your store, or a buyer interacting with the negotiation widget on a Merchant's site. It's issued by [bepleez, legal entity to be confirmed — SASU in formation].
1. Data we collect
From Merchants: account details (name, email, role), store connection data (platform, catalog, stock and margin signals you configure), billing information, and support communications.
From buyers, via the negotiation widget: the negotiation itself (messages exchanged, offers made and accepted), declared intent (what a buyer states during negotiation), and — only where a Merchant has connected it — purchase history or loyalty status. We also read publicly available product-page and storefront signals (stock, competitive pricing context) to inform an offer; this is about the product, not the buyer.
Technical data: IP address, device/browser information, and cookie identifiers described in Section 4.
2. Why we process this data, and the role of automation
Offers are generated by an algorithm that combines the signals above with the Merchant's configured guardrails (margin floor, discount ceiling). This is automated decision-making within the meaning of Article 22 of the GDPR, carried out by bepleez on the Merchant's behalf (see Section 3.1). We limit its effect deliberately:
- An offer can only ever be at or below the Merchant's own listed price — it never works against a buyer's interest relative to the price they'd otherwise see.
- Guardrails are set by the Merchant, not inferred from a buyer's protected characteristics (we do not use location as an income proxy, nor infer demographic categories).
- A buyer is never obligated to accept an offer, can always buy at the listed price instead, and can contact the Merchant to request a human review of a negotiation.
Separately, and isolated from the data used to generate your individual offer, bepleez may use aggregated and anonymized negotiation data to improve the overall performance of its model — see Section 3.2.
3. Legal basis for processing
3.1 — Running the negotiation (bepleez acts as the Merchant's processor)
When bepleez processes negotiation data to generate and run an offer on a Merchant's store, it acts on the Merchant's instructions: the Merchant determines the purpose of the processing (offering a negotiation, within which margin and discount limits), and bepleez merely carries out that instruction using its technical infrastructure. This processing is governed by a Data Processing Agreement (DPA) between bepleez and the Merchant, compliant with Article 28 of the GDPR, accepted when the Merchant signs up.
- Merchant account and billing data: performance of our contract with the Merchant.
- Buyer negotiation data used to generate an offer: processed by bepleez on the Merchant's behalf, on the legal basis the Merchant itself relies on for its commercial activity (typically its legitimate interest in offering this feature, which the buyer actively chooses to engage with).
3.2 — Improving the negotiation model (bepleez acts as controller for this processing)
Independently of running an individual negotiation, bepleez may use negotiation data, in aggregated and anonymized form, to calibrate and improve the performance of its negotiation model across its entire Merchant base. This purpose is specific to bepleez and distinct from that of any individual Merchant; bepleez is the controller for this block, on the basis of its legitimate interest in improving its service, balanced against the following safeguards:
- Data used for this purpose is aggregated and/or anonymized before processing; it does not allow an individual buyer to be re-identified.
- A Merchant can object to their negotiation data being used for this purpose, without affecting how the Service described in 3.1 runs, via their dashboard or by contacting privacy@bepleez.com.
3.3 — Non-essential cookies
Consent, collected before any such cookie is set (see Section 4).
4. Cookies
bepleez's storefront widget and marketing site use:
- Strictly necessary cookies (session state, security) — no consent required.
bpz_lead— a first-party cookie linking a visit to a tracked link (e.g., an email or webinar invitation), so a Merchant's outreach can be attributed correctly. Set only after consent, re-issued on a return visit within 7 days.bpz_consent— records the consent choice itself.
You can manage or withdraw consent at any time via "Manage cookies" in the site footer.
5. Who we share data with
We don't sell personal data. We share it with sub-processors strictly to operate the Service:
| Purpose | Provider |
|---|---|
| Application hosting | Railway, Vercel |
| Database | Supabase (PostgreSQL) |
| Cache | Upstash (Redis) |
| Authentication | Clerk |
| AI negotiation & scoring model | OpenAI |
| Market intelligence (competitive pricing signals) | PricesAPI |
| Transactional email | Resend |
| Error monitoring | Sentry |
Each is bound by its own data-processing terms with us. This list is updated as our infrastructure evolves — check back for the current version rather than relying on a saved copy.
Internal note: list to confirm before publication — verify it exactly reflects the production stack at launch time (in particular, which AI model provider(s) are actually used).
6. International transfers
Some sub-processors above (notably the AI providers) may process data outside the European Economic Area. Where that's the case, we rely on their Standard Contractual Clauses or equivalent safeguards recognized under GDPR.
7. Data retention
- Merchant account data: kept for the life of the account, plus a limited period for our legal and accounting obligations.
- Negotiation data (block A — running the Service, Section 3.1): kept for as long as needed to operate the feature, including anti-abuse and quality analysis, and not retained indefinitely after a Merchant's account is closed, beyond what applicable law requires us to keep.
- Aggregated and anonymized data (block B — model improvement, Section 3.2): once genuinely anonymized (no longer allowing a buyer to be re-identified), it may be kept beyond these periods, to the extent it no longer constitutes personal data under the GDPR.
8. Your rights
If you're in the EU/EEA, UK, or another jurisdiction with equivalent protections, you have the right to access, rectify, erase, or port your personal data, to object to or restrict certain processing, and to lodge a complaint with your local supervisory authority (in France, the CNIL).
To exercise these rights, contact privacy@bepleez.com (mailbox to be confirmed) or use the contact form. Buyers should reach out via the Merchant's own store first where the request concerns a specific purchase or negotiation, so it can be resolved quickly at the source. For the processing described in Section 3.2 (model improvement), you can exercise your right to object directly with bepleez.
9. Security
Data in transit and at rest is encrypted. Access to production systems is role-based (RBAC), Deal Tokens are cryptographically signed, and we maintain audit trails for negotiation and acceptance events. No system is perfectly secure; we ask that any suspected vulnerability be reported to security@bepleez.com (mailbox to be confirmed).
10. Children
The Service is intended for business use (Merchants) and their adult customers. We do not knowingly collect personal data from children.
11. Changes to this policy
We'll post updates here with a new "last updated" date and, for material changes affecting how we process your data, notify account owners by email.
12. Contact
privacy@bepleez.com (mailbox to be confirmed) or via the contact form.