Sovereign Data Custody & Privacy Charter

Privacy Policy & Data Governance

Domillio Sovereign Compliance Suite • Effective Date: November 4, 2026 • Version 3.2

Zero Cloud TelemetryNo third-party trackers, external behavioral analytics, or merchant fingerprinting scripts.
Sovereign CustodySingle-tenant SQLite/PostgreSQL architecture on your own hardware or dedicated Docker node.
GDPR & CCPA Built-InAutomated customer data lookup, redaction, and 48-hour purge webhooks natively supported.

1. Scope & Architecture

Domillio (“we,” “our,” or “us”) develops and maintains the Domillio Sovereign E-Commerce Compliance Suite, comprising five specialized regulatory desks:

  • Tax Exemption Desk: Wholesale B2B resale certificate collection and state revenue validation.
  • CPC Desk: Children's Product Certificates and CPSC lab testing records (16 CFR § 1110).
  • GPSR Desk: EU General Product Safety Regulation economic operator dossiers and digital product passports.
  • EPR Desk: Extended Producer Responsibility ledgers for German VerpackG and French SYDEREP declarations.
  • Prop 65 Desk: California Safe Drinking Water & Toxic Enforcement Act clear warnings and 60-day notice archives.

This policy explains how merchant business data and customer compliance filings are ingested, processed, isolated, and permanently redacted across both our cloud endpoints and sovereign self-hosted deployments.

2. Data Processed per Specialized Desk

The Suite processes only the statutory data elements required to satisfy governmental compliance mandates:

Tax Exemption Desk

Wholesale buyer business entity name, purchaser contact email, state/province of exemption, state seller permit or tax registration ID, permit issuance/expiration dates, and uploaded PDF/PNG exemption certificate scans.

Children's Product Safety (CPC Desk)

Product identifiers (SKU, title, barcode), manufacturing date and location, CPSC accredited laboratory test report numbers, and permanent tracking label metadata (15 U.S.C. § 2063).

EU GPSR & EPR Desks

EU Authorized Representative commercial name, EU physical address, regulatory contact email, German VerpackG LUCID numbers, French ADEME UIN numbers, and material weight declarations.

California Prop 65 Desk

Product chemical association data, safe-harbor warning text, truncated visitor IP hashes (for pre-purchase impression defense), and 60-day notice correspondence.

3. Zero Payment Card Data

Domillio does not collect, transmit, or store merchant payment cards or bank account numbers. All application subscription plans are processed exclusively through the official Shopify Billing API and billed directly to the merchant's regular Shopify invoice.

4. Multi-Tenant Isolation & Sovereign Self-Hosting

We enforce strict tenant boundaries at the database layer:

  • Tenant-Scoped Queries: Every database transaction is scoped strictly to the merchant's Shopify domain (shop = shopDomain). Cross-merchant data leakage is architecturally impossible.
  • HMAC Token Verification: Certificate document uploads and inspection URLs require HMAC tokens verified using constant-time cryptographic comparisons (crypto.timingSafeEqual).
  • Sovereign On-Premise Mode: For merchants deploying via Docker on Linux or Raspberry Pi 5, 100% of data remains on local physical hardware under merchant control. No compliance records leave your sovereign network.

5. Global Privacy Rights: GDPR, CCPA & CalOPPA

We honor all privacy rights under the EU General Data Protection Regulation (GDPR), the California Consumer Privacy Act as amended by the CPRA, and the UK Data Protection Act:

  • Right of Access & Portability: Merchants and wholesale buyers can export all stored certificates in standard RFC 4180 CSV or JSON format at any time.
  • Right to Rectification: Certificate records and tax identification numbers can be amended or re-submitted whenever customer credentials change.
  • Right to Erasure (Redaction): Supported natively via Shopify's mandatory compliance webhooks (customers/redact and shop/redact) and the in-app soft-delete Recycle Bin.
  • No Data Monetization: We do not sell, rent, license, or monetize customer or merchant data to data brokers or advertising networks.

6. Data Retention & Automatic Purge SLA

We retain compliance records only as long as necessary to defend merchants during statutory state tax or customs audits (typically 3 to 7 years per IRS and CDTFA rules, or until explicitly purged).

Upon receipt of an application uninstall event or Shopify shop/redact notification, all stored database records, sessions, and uploaded documents associated with that shop are permanently purged within 48 hours.

7. Security & Encryption Standards

All network transmissions are encrypted in transit using TLS 1.3 over Cloudflare Zero-Trust edge ingress. Uploaded exemption documents and audit ledgers are protected with SHA-256 cryptographic signatures.

8. Contact & Data Protection Officer

To exercise your privacy rights, request data exports, or address sovereign deployment inquiries:

Domillio Compliance & Data Privacy Desk
Apex Domain: domillio.org/apex