Legal
Data Processing Addendum
Draft, pending legal reviewNot yet reviewed by a lawyer and not binding. It will change before launch.
Draft 0.1Last updated: pending first publication
This addendum describes how Handychat processes personal data on behalf of a merchant. It is a structured draft. Clauses marked as pending will be completed in legal review.
Definitions
Terms such as controller, processor, personal data, processing, data subject and personal data breach have the meaning given in the data protection law that applies. Full definitions will be added in legal review.
Scope and roles of the parties
For personal data in shopper conversations and store data that Handychat processes to provide the service, the merchant is the controller and Handychat is the processor. For merchant account data and website data, Handychat is the controller and the Privacy Policy applies.
Processing instructions
Handychat processes personal data only on the merchant's documented instructions, which are these terms, the merchant's settings in the app, and its use of the service. Handychat will tell the merchant if it believes an instruction breaks the law.
Confidentiality
People who process personal data for Handychat are bound by confidentiality obligations.
Security measures
Handychat applies the technical and organizational measures described on the Security page and in Annex B.
Subprocessors and change notification
The merchant gives general authorization for the subprocessors listed on the Subprocessors page. Handychat will update that page before adding or replacing a subprocessor, and will offer a way to subscribe to updates and to object. The notice period will be set in legal review.
International transfers
Where personal data is transferred across borders, Handychat will use a valid transfer mechanism where the law requires one. The mechanisms will be specified in legal review.
Assistance with data subject requests
Handychat will help the merchant respond to requests from data subjects, including Shopify's customer data request and customer redact webhooks, taking into account the nature of the processing.
Personal data breach notification
Handychat will notify the merchant without undue delay after becoming aware of a personal data breach affecting the merchant's data, with the information available at that time. The exact timeframe will be set in legal review.
Audits
Handychat will make available the information reasonably needed to show compliance with this addendum and will cooperate with reasonable audit requests. The audit process will be set in legal review.
Return and deletion of data
When the merchant uninstalls the app or Shopify sends a shop redact request, Handychat deletes or returns the merchant's personal data, unless the law requires it to keep some. The timing will be set in legal review.
Liability
Liability under this addendum follows the limits in the Terms of Service.
Annexes
The annexes summarize the details of processing.
- Annex A, details of processing: the subject matter is providing the Handychat service. The data subjects are the merchant's shoppers and staff. The personal data includes conversation content, contact details and order references. The duration is the term of the service. Special categories of data are not intended to be processed.
- Annex B, technical and organizational measures: see the Security page.
- Annex C, subprocessor list: see the Subprocessors page.