Privacy policy

Draft of 7 October 2026

Tieroo puts Odoo merchants' loyalty cards into Apple Wallet and Google Wallet and keeps them up to date. This policy explains what personal data we handle, why, and what you can do about it.

1. Who we are

Tieroo is a service of Avatud Lahendused OÜ, Tartu mnt 3, 51013 Tartu, Estonia. Email: support@tieroo.com.

2. Our two roles

• Controller for the data of visitors to this website and of the merchants who sign up for Tieroo.
• Processor for the data of the merchants' customers who hold a loyalty card. The merchant is the controller of that data and decides why it is processed; we process it only on the merchant's instructions, under a data processing agreement.

3. Visitors to this website

This website sets no cookies, uses no analytics or tracking, and loads nothing from other companies: fonts and images come from our own server.

Like any web server, ours receives your IP address and the page you request in order to send it. We use these technical logs only to keep the site running and secure, and do not combine them with other data.

If you write to us by email, we use your message and address to answer you.

4. Merchants who use Tieroo

We keep the contact and billing details of the merchant's company and its contact person, and the settings of its account, to provide the service, invoice it and support it. The legal basis is our contract with the merchant and our accounting obligations.

5. Card holders

If you have a loyalty card from a shop that uses Tieroo, the shop is responsible for your data. Its customer records, points and rewards are kept in the shop's own Odoo. To build your card and keep it current, the Tieroo platform holds only:

• your name, as shown on the card;
• the points, and with Customer Levels the level, shown on the card;
• card identifiers, including the code shown as the QR code;
• the push tokens of the phones the card is on, so the card can be updated.

The platform holds no purchase history and no location: we do not track where you are.

If you join a loyalty program with a QR code, you enter your name and email address and confirm the email address (double opt-in) before the card is sent to you.

Notifications on your phone are limited to: points changed (at most once a day), a new reward available, and points or the card about to expire. You can turn them off, or remove the card, in Apple Wallet or Google Wallet at any time.

6. Sub-processors

We use these companies to run the service:

7. Where data is kept

The Tieroo platform and its daily encrypted backups are hosted in the EU, at Hetzner in Germany. When a card is added to Apple Wallet or Google Wallet, Apple or Google receive what they need to show and update it, and may process it outside the EU under the safeguards they provide for such transfers.

8. How long we keep it

• Card data: while the merchant uses Tieroo and the card exists. When a merchant leaves, we delete their card data as they instruct; backups are overwritten on a rolling basis.
• Merchant account and billing data: for the length of the contract, and invoices for as long as accounting law requires.
• Emails: as long as needed to handle the matter.

9. Your rights

Under the GDPR you can ask for access to your data, its correction or deletion, restriction of processing, a copy in a portable format, and you can object to processing.

If you hold a loyalty card, please ask the shop first: it is the controller and holds your customer record. We help the shop answer your request. You can also write to us and we will pass it on.

You can complain to the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon, aki.ee) or the authority in your own country.

10. Contact

Avatud Lahendused OÜ, Tartu mnt 3, 51013 Tartu, Estonia. support@tieroo.com.

We will publish any change to this policy on this page with a new date.