DATA PROCESSING AGREEMENT (DPA)
DATA PROCESSING AGREEMENT (DPA)
Last Updated: October 2025
- Purpose and Scope
- Definitions
- Controller: Kitsify, determining the purpose and means of processing.
- Processor: Any third-party service (e.g., Shopify Inc., Shopify International Ltd., PayPal, analytics providers, or affiliates) acting on behalf of the Controller.
- Personal Data: Any information that can identify an individual.
- Processing: Any operation performed on Personal Data, including collection, storage, or deletion.
- Processing Purpose and Legal Basis
- Fulfill product purchases, affiliate payouts, and partner agreements.
- Manage accounts, customer service, and marketing communications.
- Comply with legal, accounting, and regulatory obligations.
- Consent (e.g., marketing opt-ins, cookies).
- Contract Performance (orders, payouts).
- Legitimate Interest (fraud prevention, analytics).
- Legal Obligation (tax, invoicing, compliance).
- Roles and Responsibilities
- Kitsify ensures all Processors provide adequate safeguards.
- Processors act only on Kitsify’s written instructions.
- Kitsify maintains a record of processing activities and implements appropriate security measures.
- Data Types and Retention
- Data Transfers and Sub-Processors
- Security and Confidentiality
- Implement administrative, physical, and technical security measures to protect data.
- Restrict access to authorized personnel under confidentiality obligations.
- Promptly report any suspected breach within 72 hours of awareness.
- Data Subject Rights
- Access, correct, or delete their personal data.
- Withdraw consent.
- Request portability of records.
- Breach Notification and Assistance
- Notify affected data subjects and regulators as required.
- Provide timely information about the scope and mitigation measures.
- Term and Termination
- Governing Law