Network terms and data use

What the network does

A participating store checks Cash on Delivery against its configured rules and delivery history. Full protection can also use directly matching history from other participating stores in the same operating country. A merchant can choose its own-store scope. Other stores do not receive a customer directory or the identities of contributing shops.

Information sent to the service

Depending on the enabled features, a store sends pseudonymised email, phone and postcode identifiers; store and order references; cart amounts, currency and item counts; country, shipping selections, product/category references and attributes needed by its rules, such as weight, stock and coupon matches. Records can also include timestamps, guest/registered status, payment-attempt context and subsequent order-status changes. Available courier names and tracking numbers support shipment checks. Tracking numbers remain usable operational identifiers, not anonymous data.

The checkout protection mechanism does not send raw customer names, full postal addresses, raw email/phone values or card details. Pseudonymisation supports matching and does not make the information anonymous.

When checks and collection happen

Availability checks may run while checkout details are entered, before a payment method is selected. When an eligible physical COD order is created, its initial context and later outcomes are recorded. A cancellation alone is not proof of refusal or non-delivery. Store-reported completion is distinguished from courier-confirmed delivery.

Our legitimate interest

We rely on legitimate interests under Article 6(1)(f) GDPR to provide proportionate COD delivery-history protection: reducing avoidable losses from repeat uncollected shipments, checking relevant delivery outcomes and preserving COD for customers with a reliable history. Participating merchants have the corresponding interest in protecting their fulfilment operations. Processing is limited to the relevant purpose and is balanced against shoppers’ privacy, reasonable expectations and ability to challenge an outcome.

Network participation is not based on treating plugin activation, reading this notice or selecting COD as shopper consent. Merchants must provide their own privacy information and meet the requirements applicable to their use. Optional website analytics and advertising use separate consent. New purposes, including model development, are assessed separately.

How checkout may be affected

The store chooses the relevant rules and may hide COD, require an advance payment or request email confirmation. A match is not a finding of fraud or a public label about a person. Contact the store if you believe the result is incorrect and request a meaningful review. Whether Article 22 applies depends on the actual effects; legitimate interest alone is not an Article 22 exception.

Shared ML development

Machine learning is managed centrally for the network using eligible full-lifecycle observations and recorded outcomes. Model development and use are assessed separately from delivery-history lookups, within the stated purposes and safeguards. Where an ML score contributes to a checkout decision, its use is recorded in the decision audit.

Conditions for participating stores

• Inform shoppers before processing about the service, its purposes, relevant data, sources and rights. Keep the store’s privacy notice consistent with the enabled features and the legal basis applicable to its use.
• Supply accurate order and shipment outcomes, correct errors and provide a route for shoppers to request review. Do not describe every cancellation or courier return as a proven customer refusal.
• Use the service only for legitimate store transactions and the agreed protection purposes. Respect the applicable data-protection roles, security, retention and processing arrangements; do not use it to explore unrelated identities or create a public blacklist.

Retention and stopping participation

Retention depends on the record’s purpose, its continuing relevance to delivery-history checks, the service relationship and any obligation to preserve evidence or legal records. There is no single 90-day deletion period for all network and decision records. Stopping participation prevents future collection through that connection; it does not itself erase information already received. Requests for access, correction, objection, restriction or erasure are assessed against the relevant purpose and applicable legal requirements. The privacy notice explains specific periods used for support attachments and measurement data.

Questions, corrections and rights

For an individual checkout decision, contact the store first. For information held by Smart COD AI, contact info@woosmartcod.com. Depending on the legal basis and circumstances, you may request access, correction, erasure or restriction, object to processing, or withdraw consent where applicable. You may complain to your competent data-protection authority. Do not send card details or passwords with a request.

Related documents

• Service terms · Smart COD AI
• Privacy notice · Smart COD AI
• Legitimate-interest assessment · Smart COD AI