CTpos privacy policy

Template. This text is a draft from CTpos and must be reviewed by a lawyer and adapted to your circumstances before it is used. Remove this box when the text has been approved.

Last updated: 30-10-2026

1. Who we are

CTpos is provided by CTpos.online v. CT Consult, CVR 15847476, Platanhaven 10, 3400 Hillerød, e-mail ctconsult@tte.dk ("we").

CTpos is a point-of-sale system with a backoffice for shops. We process personal data in two roles:

• As data controller for data about our own customers (the companies that use CTpos), their contact persons and backoffice users, and for our invoicing.
• As data processor for the data the companies themselves record in CTpos about their customers and staff. The company is the data controller, and we only process the data on the company's instructions in the data processing agreement.

2. Data we process as data controller

• The company's name, CVR number, address, contact person, e-mail and phone.
• Users of the backoffice and the admin site: name, e-mail, password (only as an encrypted hash), role and chosen language.
• Invoices and payments for the use of CTpos.
• Event log of actions in the admin site (who, when, what).
• Technical cookies: login cookie (session, or 30 days with "Remember me") and a language cookie. We do not use cookies for statistics or marketing.

Purposes and legal basis: to provide and invoice CTpos (performance of the contract, GDPR art. 6(1)(b)), to comply with the Danish Bookkeeping Act (legal obligation, (c)) and to keep the system secure (legitimate interest, (f)).

3. Data we process as data processor

Depending on how the company uses CTpos, typically:

• Customers: name, phone, e-mail, address, CVR (business customers), customer account and balance, discount, notes, marketing consent.
• Orders and sales: cleaning orders, receipts, receipt copies sent by e-mail, SMS about collection.
• Staff (clerks): name, clerk number, PIN and optional password (only as a hash), role and the sales and events they made.
• Card payments: card type, masked card number and terminal reference (never the full card number).
• Appointments (when the company uses them): appointments, patch tests and colour formulas; for online payment and a card saved for a no-show fee only the payment provider's (Stripe) reference, the card brand and the last 4 digits. Health information (allergy, skin and scalp, medication, pregnancy) is stored only with the customer's explicit consent, seen only by staff with a special right, every view is logged, and it is deleted when the consent is withdrawn, on anonymisation or under the company's retention rule (default 24 months after the last visit).
• The till's camera: only used to read barcodes and QR codes. Images are processed in memory on the till and are not stored or sent.
• Error reports: when a CTpos program (till, CTpos Payment, CTpos SMS, server) has a software error, an error report with the program, version, device, company, the error and the last part of the program's error log is sent to us so we can fix the error. Phone numbers, e-mail addresses, card numbers, CPR numbers and tokens are hidden on the device and again on the server. Only our operations staff have access, and reports are deleted 90 days after the error last occurred.
• Transfer to accounting: when the company enables it, vouchers and invoices are sent to the company's own accounting system (e.g. Dinero or OFINDA).

4. Sub-processors

We use the following sub-processors: hosting of servers and databases ([hostingleverandør: skriv navn og land i teksten]), sending e-mail via SMTP ([e-mail-leverandør: E-mail (SMTP)]), the accounting systems the company chooses to connect, and for online payment Stripe on the company's own Stripe account. The list is kept up to date in the data processing agreement.

5. Retention and deletion

• Sales and bookkeeping data (journal, receipts, Z reports, SAF-T) are kept for 5 years after the end of the financial year (Danish Bookkeeping Act) and are never changed.
• Customer data is deleted or anonymised at the company's request or according to the retention rules the company has set up (e.g. inactive customers after a number of years). Anonymisation keeps the bookkeeping data but removes name, phone, e-mail and address.
• Logs are deleted after the periods that have been set up. Error reports are deleted 90 days after the error last occurred.
• Data about the company and its users is kept while the agreement runs and then for up to 5 years because of the Bookkeeping Act.

6. Security

Connections are encrypted (HTTPS), passwords and PINs are only stored as hashes, credentials for third parties are stored encrypted, and each company has its own database. Access to the backoffice is controlled with roles and permissions.

7. Your rights

You have the right of access, rectification, erasure, restriction, data portability and objection. If you are a customer of a shop that uses CTpos, contact the shop, which is the data controller; we help the shop. Contact us at ctconsult@tte.dk about data we are the controller for.

You can complain to the Danish Data Protection Agency (Datatilsynet), Carl Jacobsens Vej 35, 2500 Valby, www.datatilsynet.dk.