Company: Limoni Apps BV
Product: Discount Ninja (Shopify App)
Assessment date: January 7 2026
Reviewed by: Bart Coppens, Founder
Legal framework
Article 37(1) GDPR requires the appointment of a Data Protection Officer only where:
The controller or processor is a public authority or body; or
Core activities consist of large-scale, regular and systematic monitoring of data subjects; or
Core activities consist of large-scale processing of special categories of personal data.
Assessment
1. Public authority or body
The company is a private commercial entity and is not a public authority or body.
→ Criterion not met
2. Large-scale regular and systematic monitoring
The company’s core activities consist of providing promotional and pricing functionality to merchants via a Shopify app.
Any processing of end-customer personal data is:
Initiated by merchant configuration
Limited to specific operational purposes (e.g. enforcing one-use-per-customer promotions)
Transient and not persisted
Not used for profiling, advertising, or cross-context tracking
The company does not conduct large-scale, regular, or systematic monitoring of individuals as a core business activity.
→ Criterion not met
3. Special category data
The company does not process special category personal data (Article 9 GDPR) as part of its core activities.
→ Criterion not met
Conclusion
Based on the above assessment, the company is not required to appoint a Data Protection Officer under Article 37 GDPR.
Responsibility for GDPR compliance is assigned internally.
Signed:
Name: Bart Coppens
Role: Founder
Date: January 7 2026