TipFlow
Legal

Privacy Policy

Last updated: 5 May 2026 · Governed by Irish and EU law

1. Who we are

Tip Sort is a software-as-a-service platform that enables Irish hospitality businesses to distribute tips and gratuities to staff in compliance with the Payment of Wages (Amendment) (Tips and Gratuities) Act 2022. The platform is operated by Tip Sort (“Tip Sort”, “we”, “us”). Our contact email is info@tipsort.com.

Tip Sort acts as a data processor on behalf of the hospitality businesses (our customers) who use the platform. Those businesses are the data controllers for the personal data of their staff members. Tip Sort acts as a data controller for the personal data of the business owners and administrators who hold Tip Sort accounts.

2. What data we collect

CategoryDataPurpose
Account holdersName, email address, Google account ID (if Google sign-in used)Authentication, account management, support
Business detailsBusiness name, address, contact detailsCompliance documents, WRC notices
Staff recordsFirst name, surname, role, contracted hours, IBAN (encrypted at rest using AES-256-GCM)Tip distribution, WRC-compliant staff statements
Tip distribution dataWeekly tip pools, hours worked, payout amounts, distribution calculationsPayroll processing, compliance records
Audit logTimestamped record of all actions (who, what, when)WRC compliance, dispute resolution
Usage dataLogin events (throttled), browser type, IP addressSecurity monitoring, fraud prevention

IBANs are never stored in plaintext. All IBAN values are encrypted using AES-256-GCM before being written to the database. Only the last 4 digits are ever returned to the client interface.

3. Legal basis for processing (GDPR)

4. How we share your data

We do not sell personal data. We share data only with the following sub-processors who provide infrastructure services:

Sub-processorPurposeLocation
Clerk (Clerk.com, Inc.)User authentication and session managementUSA (SCCs in place)
Neon (Neon, Inc.)PostgreSQL database hostingEU (AWS eu-west-1)
Vercel (Vercel, Inc.)Application hosting and edge deliveryEU edge nodes

We may disclose data to the Workplace Relations Commission (WRC) or other regulatory or law enforcement bodies where required by Irish or EU law.

5. Data retention

Tip distribution records, staff statements, and audit logs are retained for a minimum of 3 years to meet WRC compliance requirements under the Payment of Wages (Amendment) (Tips and Gratuities) Act 2022. Account and business data is retained for the duration of your subscription and deleted within 90 days of account closure on request.

6. Your rights

Under GDPR (as retained in Irish law), you have the right to:

To exercise any of these rights, email info@tipsort.com. We will respond within 30 days. You also have the right to lodge a complaint with the Data Protection Commission (Ireland).

7. Security

We implement appropriate technical and organisational measures to protect personal data, including AES-256-GCM encryption for financial identifiers, role-based access controls, TLS in transit, and a full audit log of all data access and modification events.

8. Cookies

Tip Sort uses only essential session cookies required for authentication (managed by Clerk). We do not use advertising or tracking cookies.

9. Changes to this policy

We will notify account holders of material changes by email at least 14 days before they take effect. Continued use of the platform after that date constitutes acceptance.

10. Contact

For any privacy-related queries, contact us at info@tipsort.com.