OrderSay

OrderSay Privacy Policy

Last updated: 6 November 2026

This policy explains what personal data OrderSay processes, how and why it is processed, who receives it, how long it is kept, and how you can ask for it to be deleted.

1. Who we are

OrderSay is a Shopify app that gives online stores a WhatsApp support inbox on the store's own WhatsApp number. OrderSay is operated by CHATINBOX YAZILIM ARGE VE TEKNOLOJI LIMITED SIRKETI, with its registered office in Istanbul, Türkiye, Turkish tax number 2091959267 ("OrderSay", "we", "us").

Privacy enquiries: privacy@ordersay.com.

2. Our two roles

3. What data we process

3.1 Data we receive through Shopify's APIs

OrderSay asks Shopify only for read access to orders and customers (read_orders, read_customers). It never writes to the store.

We use this data to match an incoming WhatsApp message to the right customer and order, and to show the order, shipping and return details next to the conversation.

3.2 Data we receive through WhatsApp (Meta Cloud API)

Messages arrive on the merchant's own WhatsApp Business number, which stays in the merchant's own Meta account.

3.3 Data we receive from merchants and their staff

3.4 Data generated automatically

Product analytics are not enabled. We will update this policy before enabling an additional monitoring or analytics provider, and will follow the DPA's sub-processor notice procedure where it applies.

OrderSay has no storefront component. It places no cookies or trackers on the store's website and does not track how shoppers browse a store.

3.5 Visits to ordersay.com

This website sets no cookies, runs no analytics and loads nothing from other sites; its fonts and images come from ordersay.com itself. The website is hosted on Cloudflare Pages. Cloudflare processes standard request data (IP address, time, page requested, browser type) to deliver and secure the site. If you write to us by email or with the pilot form (your name, email, store address and note), the pilot form, which runs on Cloudflare Workers, sends your message through Cloudflare Email Sending to our Microsoft 365 mailbox, and we use what you send only to answer you.

4. Why we process it

We use the data only to provide the OrderSay service:

  1. Receive and send WhatsApp messages on the merchant's number and show them in a shared inbox.
  2. Match a message to the right Shopify customer and order, and show order, shipping and return information.
  3. Help staff answer "where is my order?" questions from verified order and tracking data. Order-status replies are sent automatically only when the merchant switches on automatic answers outside business hours.
  4. Assign conversations to staff; once AI-assisted features are available (section 4.1), group and prioritise conversations as tasks with an explainable score.
  5. Keep the service secure: authentication, abuse prevention, audit logs, error records.
  6. Provide support, run billing through Shopify, and meet legal obligations.

We do not sell personal data. We do not use it for advertising, and we do not combine data from different stores. Each store's data is kept separate from every other store's data.

Marketing messages: the merchant is responsible for collecting opt-in consent before sending WhatsApp marketing templates. OrderSay blocks marketing templates to customers without a recorded opt-in, and every template to a customer who has opted out (section 3.2).

4.1 AI-assisted features

AI-assisted features are not available yet, and no conversation content is sent to an AI provider. Before AI processing becomes available, we will update this policy and the sub-processor list to identify the enabled models, recipients, processing locations and applicable retention exceptions, with the notice period set out in the DPA. AI processing will run only for a merchant that turns it on.

5.1 EU and UK (GDPR)

5.2 Türkiye (KVKK, Law No. 6698)

For our own controller activities, we rely on Article 5(2)(c) for processing necessary for a contract with the individual, Article 5(2)(ç) for applicable legal record-keeping duties, and Article 5(2)(f) for necessary business-contact, enquiry and security processing that does not override individuals' fundamental rights and freedoms.

6. Where the data is stored and who receives it

Our application, database and queue are hosted by Render in Frankfurt, Germany. Message attachments are not stored yet; before we start storing them, we will add the storage provider and its location to this policy and to the sub-processor list, with the notice set out in the DPA. Other providers process data in the locations shown below.

Providers that process store data on our behalf (sub-processors). Each must be bound by a data processing agreement with us before it processes store data:

ProviderPurposeLocation
RenderApplication hosting: web service with its background jobs, PostgreSQL database and Key Value store (queue)EU (Frankfurt, Germany)
Microsoft (Microsoft 365)Company email, when a merchant's support request contains store dataMicrosoft data centres; we are confirming the region of our account

Providers under the merchant's own agreements. The merchant uses Shopify and the WhatsApp Business Platform under its own agreements with them. They process data under those agreements, not as our sub-processors:

ProviderPurposeLocation
ShopifyApp platform, store and order data, billingAs described in Shopify's own privacy terms
WhatsApp Ireland Limited or the other WhatsApp company named in the merchant's agreement (WhatsApp Business Platform)Sending and receiving WhatsApp messages on the store's own numberEU / USA

Providers for our own business (we are the controller).

ProviderPurposeLocation
Cloudflare, Inc. (Pages, Workers, Email Sending)Hosting ordersay.com; running the pilot form and passing its messages to our mailboxCloudflare's global network
Microsoft (Microsoft 365)Company email: service and billing emails to merchants, privacy and support requestsMicrosoft data centres; we are confirming the region of our account

Render, Cloudflare and Microsoft belong to groups headquartered in the USA. Our team works from Türkiye, so authorised staff may access data from outside the EU, and WhatsApp and other Meta group companies may process WhatsApp data in the USA.

The applicable transfer mechanism for each recipient and processing activity is being documented with our lawyer. Transfers that require safeguards will not begin until those safeguards are in place. Where Turkish law (KVKK) applies to a transfer abroad, the mechanism required by Article 9 of Law No. 6698 must be in place before the transfer begins; EU Standard Contractual Clauses do not replace Turkish requirements. You can ask for a copy of the applicable safeguards at privacy@ordersay.com; we may redact commercial terms.

The same list of sub-processors, with the notice period for changes, is on our sub-processor page. We will update both before we add a new sub-processor.

We disclose data to authorities only when the law requires it.

7. How long we keep it

DataRetentionCounted from
Message content and conversation history12 monthsThe date each message was received or sent
Message attachments (media), once storage is switched on (section 6)90 daysThe date the attachment was received or sent
Incoming WhatsApp notifications that could not be processed (they can contain a phone number, a profile name and message text)7 daysThe time processing finally failed
Tasks and task history12 monthsThe date of each task entry
Audit logs24 months; when a store's data is deleted, its entries lose the link to the store and are kept for the rest of that period; entries keep the identifiers they record, for example Shopify customer and order numbers, the WhatsApp number's Meta identifier, and the store's identifiers in the entries for the store deletion request and for the deletion itselfThe date of each entry
Customer contact records (WhatsApp phone number, profile name and the matched Shopify customer identifier), opt-out records and order matchesNo fixed period: kept while the store uses OrderSay; deleted when the store forwards that customer's deletion request (section 8), or with the rest of the store's data after uninstallThe deletion request the store forwards, or receipt of Shopify's store deletion request
Data of a deleted customerDeleted on request (see section 8); audit log entries that refer to the customer only by identifiers (for example, that a staff member opened their order card) and a "deleted" entry are kept until their 24 months end; the customer's Shopify identifier is kept as a deletion marker, so that their data is not tied to a conversation again, until the store's data is deletedThe deletion request the store forwards
Store data after uninstallDeleted within 30 daysReceipt of Shopify's store deletion request (see section 8)
Merchant account recordsUntil the store's data is deleted after uninstallUninstall
Support correspondenceAs long as needed to handle the request and its follow-up; we are setting a fixed periodThe date the request is closed
Pilot-form and website enquiriesAs long as needed to answer you and follow up on the pilot; we are setting a fixed periodThe date of the last contact
Server logs and error recordsAs long as our hosting provider keeps them; we are setting a fixed periodThe date of each entry
Accounting recordsThe period that Turkish tax and commercial law requiresAs set by that law

Earlier deletion obligations and valid merchant instructions take precedence where they apply.

8. How to request deletion of your data

Store customers. Ask the store you bought from. When the store forwards the request through Shopify, we delete that person's contact record, messages, order matches and attachments; order details held briefly in the server's memory are no longer used after five minutes and are cleared from memory later, at the latest when the server restarts. You can also email us at privacy@ordersay.com with the store's name and the phone number you used on WhatsApp. We will forward the request to the store and act on the store's instructions.

Merchants. Uninstalling OrderSay disconnects your WhatsApp number from OrderSay. Your WhatsApp Business account and number stay in your own Meta account. Following uninstall, Shopify normally sends us a store deletion request 48 hours later. Authorised staff complete the deletion within 30 days after we receive that request, subject only to the legal-retention exceptions in section 7 and the DPA. Self-service data export is not available. You can ask for a copy of your store's data at privacy@ordersay.com before you uninstall or within 7 days after uninstalling; we send it within 14 days of the request and before the deletion is completed. Unless the store owner asks us to delete earlier, we do not start deleting a store's data before that 7-day window has ended or while a requested copy has not been sent. If we end your access (Terms of Service, section 9), you can ask for a copy within 30 days; we delete the data once the copy is sent or the 30 days pass without a request. To request deletion earlier, email privacy@ordersay.com; we confirm the request with the store before deleting.

Our own users. If you are a merchant's account contact or wrote to us through the website, you can request access to, correction of or deletion of your data at privacy@ordersay.com.

Where we act as controller under the GDPR, we respond without undue delay and within one month of receipt; if Article 12(3) allows an extension, we tell you within that first month. Requests under KVKK are answered within 30 days. When we act as processor, we pass the request to the store without undue delay; forwarding it does not extend the store's own deadline.

9. Your rights

Your rights depend on the law that applies to the processing concerned. Under the GDPR you may have the right to access, correct, delete or export your personal data, to restrict processing, and to withdraw consent. Mexico's LFPDPPP gives "ARCO" rights.

Right to object. You may object, on grounds relating to your particular situation, to processing based on our legitimate interests (section 5.1).

Under KVKK Article 11 you may also ask whether and how your data is processed, learn its purposes and recipients in Türkiye or abroad, ask for corrections or erasure and for those to be notified to recipients, object to a result against you that arises solely from automated analysis, and claim compensation for damage caused by unlawful processing.

If we process your data as a processor for a store, we pass your request to that store. You can also complain to your data protection authority. In Spain this is the Agencia Española de Protección de Datos (aepd.es); in Türkiye, the Kişisel Verileri Koruma Kurumu (kvkk.gov.tr).

10. Security

11. Children

OrderSay is a business tool. It is not directed at children.

12. Changes to this policy

We will publish any change on this page and update the date above. Before a material change takes effect, we will notify merchants in the app or by email.

13. Contact

CHATINBOX YAZILIM ARGE VE TEKNOLOJI LIMITED SIRKETI, Istanbul, Türkiye
Email: privacy@ordersay.com