Legal

Privacy Policy

Last updated: 28 September 2026

This policy explains what personal data we collect when you use Tillvera, why we collect it, who we share it with, and the rights you have. We have tried to write it in plain English. If anything is unclear, email support@tillvera.com.

1. Who we are

Tillvera is a trading name of Carpanini Group Ltd, a company registered in England and Wales (company number 17134854), registered office: 44 Frogmore Street, Abergavenny, NP7 5AN. In this policy, “Tillvera”, “we”, “us” and “our” mean Carpanini Group Ltd.

We are the data controller for the personal data described in this policy, which means we decide how and why it is used. We are registered with the UK Information Commissioner's Office (ICO). Our registration reference is ZC259314.

Contact for all privacy matters: support@tillvera.com (please put “Privacy” in the subject line).

2. What data we collect

Account data

Your name, email address, password (stored only as a secure hash), business and store names, and your role (for example owner or manager).

Business data you upload

Sales reports, wage figures, product and category data, and other files you upload or send from a connected EPOS or accounting system (such as Xero). This data belongs to you. It is mostly business information, but it can include personal data — for example staff names in a wage file. You are responsible for having the right to upload it.

AI Coach conversations

The questions you ask the AI Coach, the answers it gives, and a summary of your store's figures used to answer them.

Payment and billing data

Your plan, billing history, invoices and billing address. Card details are collected and stored by Stripe, not by us — we only see a payment reference, the card brand and the last four digits.

Usage and technical data

IP address, browser and device type, pages visited, actions taken in the app, timestamps and error logs.

Communications

Emails and support messages you send us, and your marketing preferences.

3. Why we use your data and our lawful basis

Under UK GDPR (and EU GDPR where it applies) we must have a lawful basis for each use of your personal data:

What we doLawful basis
Create and run your account; store your business data; show your dashboards; answer AI Coach questions; send service emails (password resets, billing notices, important changes)Contract — Art. 6(1)(b). Necessary to provide the service you signed up for.
Take payments, issue invoices, keep tax and accounting recordsContract and Legal obligation — Art. 6(1)(b) and 6(1)(c). HMRC requires us to keep financial records.
Usage analytics and error logs to understand how the product is used and improve itLegitimate interests — Art. 6(1)(f). Our interest in improving the service. You can object (see section 8).
Security monitoring, fraud and abuse preventionLegitimate interests — Art. 6(1)(f). Keeping the platform and your data safe.
Marketing emails (tips, newsletters, offers)Consent — Art. 6(1)(a), or the “soft opt-in” for existing customers (see section 4). You can withdraw at any time.
Responding to legal claims or requests from authoritiesLegal obligation — Art. 6(1)(c), or Legitimate interests in defending legal claims.

We do not sell your personal data, we do not use your business data to train AI models, and we do not make decisions about you based solely on automated processing that have legal or similarly significant effects. AI Coach answers are suggestions only.

4. Marketing emails

We follow the UK Privacy and Electronic Communications Regulations (PECR):

  • If you are not a customer, we only send marketing emails if you have explicitly opted in. We never use pre-ticked boxes.
  • If you are a customer or trial user, we may email you about similar Tillvera products and features (the “soft opt-in”). When you create an account you can choose not to receive those emails, and you can opt out at any time.
  • Every marketing email includes an unsubscribe link. One click removes you, and we act on it immediately — no login needed.
  • You can also opt out by emailing support@tillvera.com.
  • We do not send marketing by SMS or make marketing phone calls.

Unsubscribing from marketing does not stop essential service emails, such as password resets, billing receipts, and notices about changes to these terms.

5. Who we share data with

We use a small number of trusted service providers (“processors”) to run Tillvera. Each one is bound by a contract that only allows them to use your data on our instructions and to keep it secure.

ProviderWhat they doLocation
Supabase, Inc.Database, file storage and loginEU data centres; company based in the US
Vercel, Inc.Website and app hostingUS, with global edge network
Anthropic, PBCGenerates AI Coach answersUS
OpenAI, L.L.C.Processes AI Coach question text to search our Retail School knowledge baseUS
Stripe Payments Europe, Ltd. / Stripe, Inc.Payments and billingEU / US
Resend, Inc.Sends our emailsUS

Our AI providers (Anthropic and OpenAI) are contractually prohibited from using data sent through their business APIs to train their models.

If you choose to connect a third-party service (for example Xero or your EPOS provider), data is exchanged with that service on your instruction and under their own privacy policy.

We may also share data with professional advisers (lawyers, accountants), with authorities where the law requires it, or with a buyer if our business is sold — in which case this policy will continue to apply to your data.

6. International transfers

Some of our providers are based in, or access data from, the United States. When personal data leaves the UK or European Economic Area, we make sure it is protected by one of the following safeguards:

  • UK Extension to the EU–US Data Privacy Framework (“UK–US data bridge”) and the EU–US Data Privacy Framework, where the provider is certified;
  • Standard Contractual Clauses approved by the European Commission, together with the UK International Data Transfer Addendum, where the provider is not certified;
  • an adequacy decision, where data goes to a country the UK or EU has recognised as providing adequate protection (for example, UK ↔ EU transfers).

You can ask us for details of the safeguard used for any provider by emailing support@tillvera.com.

7. How long we keep your data

DataHow long
Account and billing records6 years after your last login, to meet UK tax and accounting record requirements
Uploaded sales and business data (including AI Coach history)While your account is open, then deleted 90 days after your account is closed
Marketing preferencesUntil you withdraw consent. After that we keep only your email on a suppression list so we never email you again
Server and security logsUp to 90 days, unless needed to investigate an incident
Support emailsUp to 2 years after the conversation ends

If you ask us to delete your data, we delete everything we are not legally required to keep. Records we must keep for tax purposes are restricted so they can only be used for that purpose.

8. Your rights

You have the following rights under UK GDPR (and EU GDPR if you are in the EU). To use any of them, email support@tillvera.com from the address linked to your account. It is free. We will respond within one month (30 days); if a request is complex we may extend this by up to two further months and will tell you why. We may need to confirm your identity first.

  • Right of access (Subject Access Request). Ask for a copy of the personal data we hold about you and how we use it. Email support@tillvera.com with the subject “Subject Access Request”.
  • Right to rectification. Correct inaccurate or incomplete data. You can update most details yourself in Settings → Profile, or email us.
  • Right to erasure (“right to be forgotten”). Ask us to delete your data. You can delete your account yourself in Settings → Profile → Delete account, or email us. We will keep only what the law requires (see section 7).
  • Right to restriction of processing. Ask us to pause using your data — for example while we check whether it is accurate, or if you have objected to its use.
  • Right to data portability. Receive the data you gave us in a common machine-readable format (such as CSV or JSON), or ask us to send it to another provider.
  • Right to object. Object to us using your data on the basis of legitimate interests (such as analytics). You have an absolute right to object to direct marketing — we will stop immediately, with no exceptions.
  • Right to withdraw consent. Where we rely on consent, you can withdraw it at any time. This does not affect anything we did before you withdrew it.

9. Cookies

We only use strictly necessary cookies and similar browser storage. These do not need your consent under PECR because the service cannot work without them:

  • Supabase authentication session — keeps you logged in securely.
  • Cookie notice preference — remembers that you have seen our cookie notice.

We do not currently use analytics, advertising or third-party tracking cookies. If we add any analytics tool (for example Vercel Analytics or PostHog) that stores or reads information on your device, we will list it here and ask for your consent through a cookie banner before it runs.

You can block cookies in your browser settings, but you will not be able to log in.

10. Security and data breaches

We protect your data with encryption in transit (HTTPS) and at rest, access controls so each account can only see its own data, and restricted staff access. No system is perfectly secure, but we work hard to keep yours safe.

If a personal data breach happens, we will report it to the ICO within 72 hours of becoming aware of it where required. If the breach is likely to put your rights and freedoms at risk, we will also tell you directly within 72 hours of becoming aware of it, explaining what happened, what data was affected, and what you can do.

11. Users in the European Union

Tillvera is offered to retailers in the United Kingdom. We have not appointed a representative in the EU because we do not offer the service to people in the EU or EEA.

If you are in the EU or EEA and you have an account, the EU GDPR also applies. You have the same rights described in section 8. Email support@tillvera.com and we will help. You can also complain to the data protection authority in the country where you live or work. A list is available from the European Data Protection Board.

12. California residents (CCPA / CPRA)

If you live in California, the California Consumer Privacy Act gives you additional rights.

Categories of personal information we collect

  • Identifiers — name, email address, IP address, account ID.
  • Commercial information — plan, billing and purchase history.
  • Internet or network activity — pages visited and actions in the app.
  • Professional or employment-related information — business name, store details, your role.
  • Other information you provide — AI Coach questions and uploaded business data.

We collect this from you directly, from your use of the platform, and from services you connect. We use it for the purposes set out in section 3 and disclose it only to the providers listed in section 5, for business purposes.

We do not sell your personal information, and we do not share it for cross-context behavioural advertising. We have not done so in the past 12 months.

Your California rights

  • Right to know what personal information we collect, use and disclose, and to get a copy.
  • Right to delete personal information we collected from you, subject to legal exceptions.
  • Right to correct inaccurate personal information.
  • Right to opt out of sale or sharing — we do not sell or share, so there is nothing to opt out of, but you may still contact us.
  • Right to non-discrimination — we will not charge you a different price, give you a lower quality of service, or deny you service because you used any of these rights.

To make a request, email support@tillvera.com with the subject “California Privacy Request”. You may use an authorised agent. We will confirm receipt within 10 business days and respond within 45 days.

13. Children

Tillvera is a business tool for people aged 18 and over. We do not knowingly collect personal data from children.

14. Changes to this policy

If we make a significant change to this policy, we will email you at least 14 days before it takes effect and update the “Last updated” date above. Where a change requires your consent, we will ask for it.

15. Contact and complaints

Questions or requests: support@tillvera.com. Post: Carpanini Group Ltd, 44 Frogmore Street, Abergavenny, NP7 5AN.

If you are unhappy with how we have handled your data, please contact us first so we can try to put it right. You also have the right to complain to the UK Information Commissioner's Office at any time: