Privacy Policy

Last updated: 5 June 2026

This Privacy Policy explains how personal data is processed in connection with the SellerLedger ES application (the "Application"), an order-management and fulfilment integration used to operate a retail business on the Temu marketplace. It is written to comply with Regulation (EU) 2016/679 (the "GDPR") and applicable Spanish data protection law.

1. Data Controller

The data controller responsible for the processing described here is the operator of the SellerLedger ES Temu store, established in Spain.

ControllerOperator of "SellerLedger ES" (Spain)
Contact for privacy requestssaucone5@gmail.com
Country of establishmentSpain (European Union)

2. What personal data we process

We process the minimum personal data required to fulfil customer orders placed on the Temu marketplace:

We do not process payment card data, and we do not knowingly process special categories of personal data.

3. Purposes and legal bases

PurposeLegal basis (GDPR Art. 6)
Processing and fulfilling customer orders (shipping the product to the buyer)Performance of a contract — Art. 6(1)(b)
Handling returns, refunds and customer-service requestsPerformance of a contract — Art. 6(1)(b)
Keeping accounting and transaction recordsCompliance with a legal obligation — Art. 6(1)(c)
Preventing fraud and securing our systemsLegitimate interests — Art. 6(1)(f)

4. Recipients and sub-processors

Personal data is shared only with the parties strictly necessary to fulfil orders:

RecipientRoleLocation
Hetzner Online GmbHCloud hosting / data storage (sub-processor)Germany (EU)
CJ Dropshipping (Dongguan Qinweng Network Technology Co., Ltd.)Order fulfilment & logistics (sub-processor)Outside the EEA
Whaleco Inc. / TemuMarketplace through which orders are receivedEU / international

5. International transfers

Where personal data is transferred to a sub-processor located outside the European Economic Area (for example, for order fulfilment), such transfers are protected by appropriate safeguards under GDPR Chapter V, including the European Commission's Standard Contractual Clauses and, where required, supplementary measures.

6. Retention

Personal data is deleted within 30 days of an order being completed, except where retention is required to comply with a legal obligation. In particular, invoicing and accounting records are retained for the periods required by Spanish tax and commercial law (Art. 30 of the Spanish Commercial Code — Código de Comercio — and Art. 66 of the General Tax Law — Ley General Tributaria 58/2003), after which they are securely deleted.

7. Security measures

We apply appropriate technical and organisational measures, including encryption of data in transit (TLS 1.2 or higher), access control and authentication for any system that can query personal data, the principle of least privilege, and logging of access to personal data.

8. Your rights

Under the GDPR you have the right to access, rectify, erase, restrict or object to the processing of your personal data, and the right to data portability. To exercise these rights, contact saucone5@gmail.com. You also have the right to lodge a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos, AEPD — www.aepd.es).

9. Data breach notification

In the event of a suspected or confirmed personal data breach, we will notify the competent supervisory authority (AEPD) without undue delay and, where required, within 72 hours, in accordance with GDPR Art. 33, and will notify affected partners (including Temu) and data subjects where applicable.

10. Changes to this policy

We may update this Privacy Policy from time to time. The "Last updated" date at the top of this page reflects the most recent revision.