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Privacy Policy

Last updated: March 25, 2026

H
Written by Hayko

Privacy Policy

Last updated: 19 September 2026

Data Controller

This Privacy Policy explains how QrX B.V. ("QrX", "we", "us", "our") collects, uses, stores and protects personal data when you use our platform, websites, mobile applications and services (together, the "Services"). QrX B.V. is the controller for account, billing, website, support and security data described below. When a merchant uses QrX to process consignee or consumer data for shipments and Payment on Delivery, QrX acts as processor for that merchant.

QrX B.V.
Deventerweg 2A, 3843 GD Harderwijk, The Netherlands
KVK: 99715554
BTW: NL869103076B01
Phone: +31 85 888 7158
Email: [email protected]

1. Controller and Processor Roles

QrX has two GDPR roles. For merchant users, website visitors, support contacts and our own billing and security logs, QrX B.V. is the controller. We decide the purposes and means of that processing.

For personal data that a merchant uploads or sends to QrX so we can create shipments, deliver PIN codes, collect Payment on Delivery, handle returns or send transactional messages to that merchant's customers (consignees), the merchant is the controller and QrX B.V. is the processor. We process that data only on the merchant's documented instructions, as set out in the Data Processing Addendum (verwerkersovereenkomst).

The Data Processing Addendum that applies when QrX acts as processor is published at https://qrx.eu/data-processing-addendum.

2. What Personal Data We Collect

The personal data we collect depends on how you interact with our Services:

  • Account information: name, email address, phone number, company name, business registration details and login credentials when you create a QrX account.

  • Transaction data: payment amounts, payment status, order references, delivery addresses, QR code scan events and payment confirmations processed through our platform.

  • Financial information: bank account details (IBAN), billing addresses, invoicing data and payment settlement information necessary to process transactions.

  • Technical data: IP address, browser type, device identifiers, operating system, screen resolution and usage analytics collected automatically when you access our Services.

  • Communication data: messages, support requests, feedback and correspondence exchanged with our team.

  • Delivery data: carrier information, tracking numbers, delivery status updates and proof-of-delivery records related to QrX On Delivery flows.

  • Merchant consignee data (processor role): name, address, email, phone, order reference, parcel and payment status of a merchant's customers, processed only to provide the Services the merchant requested.

3. How We Use Your Information

We process personal data only for specific, legitimate purposes:

  • To provide and operate our payment services, including QR code generation, payment processing, delivery coordination and real-time transaction tracking.

  • To verify your identity, authenticate your account and maintain the security of our platform through fraud detection and prevention measures.

  • To communicate with you about your account, transactions and service updates, and to respond to your support requests.

  • To process settlements, generate invoices and manage billing in accordance with your merchant agreement.

  • To improve our platform's performance, develop new features and analyse usage patterns to enhance the user experience.

  • To comply with legal obligations including tax reporting, anti-money laundering regulations and financial record-keeping requirements under Dutch and EU law.

4. Legal Basis for Processing

Under the GDPR, we process personal data based on the following legal grounds:

  • Contract performance: processing necessary to provide our Services to merchants, carriers and customers, including account management and payment processing.

  • Legitimate interests: processing necessary for fraud prevention, platform security, service improvement and business analytics, where these interests are not overridden by your rights.

  • Legal obligations: processing required to comply with Dutch tax law, financial regulations, anti-money laundering legislation and other mandatory legal requirements.

  • Consent: where we rely on your explicit consent, for example for marketing communications or optional analytics cookies. You may withdraw consent at any time.

  • Processor instructions: where QrX acts as processor, we process consignee data on the merchant's documented instructions and on the legal bases that merchant determines as controller.

5. Data Sharing

We share personal data only when necessary for the purposes described in this policy. Recipients include:

  • Payment service providers: Stripe, Mollie and MultiSafePay process payments. Each payment service provider acts as an independent controller or as a processor, depending on the payment flow and its own terms.

  • Delivery partners: carriers such as UPS, GLS and Peddler receive delivery and payment data necessary to coordinate QrX On Delivery operations.

  • Cloud infrastructure: we host the Services on Google Cloud (including Cloud Run) in the European Economic Area, with related Google services needed to run the platform. Cloudflare provides infrastructure, content delivery and file storage.

  • Communication providers: Bird (SMS and WhatsApp), SendGrid (email) and Firebase (push notifications) process contact data to deliver transactional messages.

  • Analytics and monitoring: Sentry for error tracking, Microsoft Clarity for website and consumer payment page analytics and session insights, and Intercom for customer support, each bound by a data processing agreement.

  • Public authorities: we disclose data when required by Dutch or EU law, a binding court order, or a competent supervisory authority.

We never sell your personal data to third parties. All processors and partners are contractually bound to process data securely and in compliance with applicable law.

6. Sub-processors

When QrX acts as processor, we use the following categories of sub-processors. A current list is also in the Data Processing Addendum. We remain responsible for their processing under Article 28 GDPR.

  • Google Cloud and Firebase: hosting, storage, application runtime and push notifications.

  • Cloudflare: infrastructure, content delivery and file storage.

  • Stripe, Mollie and MultiSafePay: payment collection and settlement.

  • Bird (MessageBird): SMS, WhatsApp and related messaging used for PIN delivery and transactional notices.

  • SendGrid: transactional email delivery.

  • UPS and other carriers selected for a shipment: name, address and parcel data required to transport the order.

  • Sentry (error monitoring), Microsoft Clarity (website and consumer payment page analytics and session insights) and Intercom (customer support): each bound by a data processing agreement.

7. International Data Transfers

QrX primarily stores and processes data within the European Economic Area (EEA). Where data is transferred outside the EEA, for example to service providers in the United States, we ensure appropriate safeguards are in place, including EU Standard Contractual Clauses (SCCs), data processing agreements with adequate security requirements, and technical protections such as encryption in transit and at rest. We regularly assess the data protection practices of our international service providers.

8. Data Security

We implement industry-standard technical and organisational measures to protect your personal data, including HMAC-signed API requests for request integrity, encrypted data transmission using TLS 1.2 or higher, secure payment processing through PCI DSS-certified payment service providers, strict access controls with role-based permissions and multi-factor authentication, regular security assessments and vulnerability monitoring via Sentry, and encrypted backup and disaster recovery systems. No system can guarantee absolute security. You are responsible for keeping your own login credentials confidential.

9. Data Retention

We keep personal data only while necessary for its stated purpose, then delete it or render it genuinely anonymous. Internal identifiers are not automatically anonymous. Necessary operational data remains available during the service relationship.

This retention policy was adopted on 18 September 2026. It replaces the previous general periods of 12 months after account closure, 24 months for technical logs and 36 months for communications. These are approved retention targets. Automated deletion and backup expiry controls are still being implemented and verified, so existing copies may remain beyond these targets during implementation. This does not suspend individual rights or statutory deadlines. Contact us through the rights procedure in this policy for an individual assessment and the actual status of your data.

  • Operational data and exclusively owned files: deleted without undue delay during confirmed customer deletion once no longer needed, with no additional standard waiting period. An open obligation preserves only necessary evidence, not the entire account.

  • Necessary QrX fiscal records: 7 years from the applicable statutory starting point; 10 years only for an applicable longer category, such as OSS/IOSS or property records. For Dutch fiscal administration, the period starts when the data loses its current relevance. Closing an account does not restart it. This does not apply automatically to every transaction detail or file.

  • Ordinary email and technical logs: at most 30 days from original registration. Reliably attributable unnecessary customer logs are deleted earlier during customer deletion. Later events do not restart the original message's period.

  • Necessary security and access logs: at most 90 days from the event. Minimal deletion accountability records are kept at most 24 months after completion, limited to necessary references, actor, policy version, counts and outcomes, without a copy of deleted content.

  • Restricted disaster-recovery backups: at most 190 days from archive creation, with earlier targeted erasure where safely possible. Before restored data is made available, prior deletions are reapplied using the current independent deletion register.

  • Invoices, settlement documents and necessary evidence: follow the underlying record's period. Other correspondence and files are classified by purpose; no indefinite retention follows from this schedule.

A specific legal duty, claim or investigation may justify retaining only the necessary evidence. Each such exception has an owner, a reason and a review at least every 90 days, and access is restricted to that purpose. For data processed on a merchant's behalf, the merchant's valid instructions and the Data Processing Addendum apply, subject to applicable law. Independent providers may have their own legal retention duties, and deletion at QrX does not establish deletion by those providers. These periods are not universal GDPR deadlines: data must be deleted earlier when no longer necessary or when a valid request requires it.

10. Your Rights Under the GDPR

Under the General Data Protection Regulation, you have the following rights regarding your personal data:

  • Right of access: request a copy of the personal data we hold about you.

  • Right to rectification: request correction of inaccurate or incomplete personal data.

  • Right to erasure: request deletion of your personal data where there is no compelling reason for continued processing ("right to be forgotten").

  • Right to restriction: request that we limit the processing of your data in certain circumstances.

  • Right to data portability: receive your personal data in a structured, machine-readable format and transmit it to another controller.

  • Right to object: object to processing based on legitimate interests, including direct marketing.

  • Right to withdraw consent: where processing is based on consent, withdraw it at any time without affecting the lawfulness of prior processing.

  • Right to lodge a complaint: you may complain to a supervisory authority, in particular in the EU member state of your habitual residence, place of work, or of an alleged infringement.

To exercise any of these rights, contact us at [email protected]. We will respond within 30 days.

11. Supervisory Authority

For QrX B.V. the lead supervisory authority is the Dutch Autoriteit Persoonsgegevens (AP), PO Box 93374, 2509 AJ The Hague, the Netherlands, www.autoriteitpersoonsgegevens.nl.

12. Automated Decision-Making

QrX does not take decisions based solely on automated processing, including profiling, that produce legal effects concerning you or similarly significantly affect you within the meaning of Article 22 GDPR. Payment success or failure is determined by the licensed payment service provider. Fraud and security checks may flag a transaction for review; a human can review those flags on request.

13. Cookies and Tracking

Our platform uses cookies and similar technologies for authentication, preferences and analytics. Essential cookies are required for the platform to function. Non-essential cookies are only placed with your consent. For full details, please read our Cookie Policy.

14. Children's Privacy

QrX services are designed for businesses and adult consumers. We do not knowingly collect personal data from children under the age of 16. If we discover that we have inadvertently collected data from a child, we will delete it promptly. If you believe a child has provided us with personal data, please contact us at [email protected].

15. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies or legal requirements. The most recent version is always published on our website with the updated effective date. Where changes are significant, we will notify you by email or through the platform before they take effect. The full, current policy is at https://qrx.eu/privacy-policy.

16. Contact Us

If you have questions about this Privacy Policy, wish to exercise your data protection rights, or have concerns about how we handle your personal data, please contact our Data Protection Officer:

Company: QrX B.V.
​ Address: Deventerweg 2A, 3843 GD Harderwijk, The Netherlands
​ KVK: 99715554
​ BTW: NL869103076B01
​ Phone: +31 85 888 7158
​ Privacy: [email protected]
​ Support: [email protected]

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