Data Processing Addendum Summary
Last updated: October 21, 2026
This page summarizes the data processing terms we offer to business clients whose personal data we handle while providing services. It is a summary, not a signed data processing agreement and not executed Standard Contractual Clauses. To sign a full agreement with the transfer clauses and annexes completed, contact .
Roles
You (the client) are the controller of personal data in your systems. When we work on those systems, we are your processor (a "service provider" or "contractor" under US state laws). We process the data only on your documented instructions.
Our commitments as processor
Our standard data processing agreement follows Article 28 of the GDPR and UK GDPR:
- Process personal data only on your instructions, including for international transfers, unless the law requires otherwise.
- Make sure everyone who accesses the data is bound by confidentiality.
- Apply security measures that fit the risk, as listed in the agreement.
- Use subprocessors only with your general or specific authorization, inform you of changes, and let you object.
- Help you respond to data subject requests and meet your security, breach-notification, and impact-assessment obligations.
- Notify you without undue delay after confirming a personal data breach affecting your data.
- At the end of the engagement, return or delete your personal data, as you choose, unless the law requires us to keep it.
- Give you the information needed to show compliance and allow reasonable audits.
International transfers
We are based in Vietnam. When personal data from the EEA, UK, or Switzerland is transferred to us or our subprocessors, the signed agreement includes the European Commission's Standard Contractual Clauses (Module 2 or 3), plus the UK Addendum or Swiss amendments where needed.
Subprocessors
The subprocessors we use depend on the engagement and are listed in the signed agreement. They commonly include Cloudflare, our email provider, and the platforms you choose, such as Shopify, AWS, or Google Cloud.