Data processing agreement
This agreement is part of the terms of use. It applies as soon as you have personal data of others processed through StoreBOS, such as the customers of your webshop. You are then the controller and we are the processor (art. 28 GDPR).
The agreement itself
We use the standard clauses of the European Commission, UNCHANGED: Implementing Decision (EU) 2021/915, annex. The text is available in English on EUR-Lex. Those clauses satisfy art. 28(3) and (4) GDPR. What follows below are only the appendices that the standard clauses ask to be filled in.
For this agreement we choose, within the standard clauses: option 2 in clause 7.7 (general written authorisation for sub-processors, with prior notice of at least 30 days), and the notification of a breach under clause 9.
Appendix I - Parties
| Controller | Processor | |
|---|---|---|
| Who | you: the name under which you made your request | StoreBon |
| Address, email, Chamber of Commerce no. | as recorded with your request | see below |
| Privacy contact | the email address of your request | the email address below |
The details of StoreBon (the processor), taken straight from the page Company details:
Appendix II - What we process for you
| Item | Details |
|---|---|
| Subject matter | hosting and serving your website and webshop |
| Duration | as long as you have a site with us; afterwards 30 days to export |
| Nature and purpose | storing, displaying, forwarding and keeping, to make your site and shop work |
| Data subjects | your customers and visitors, and anyone who contacts you through your site |
| Types of data | name, address, email address, phone number, order data and messages; and, once the customer chat is available, the messages someone types in that chat and the email address they leave there |
| Special categories of data | none; do not put them on your site either |
| Instructions | your use of the admin screens; we process nothing for our own purposes |
| End | we delete the data after the export period, unless the law requires us to keep it; backups that still contain your data then expire by themselves, at the latest 52 days later |
| Chat messages and email address left behind | we keep them with the ticket the conversation belongs to and delete them together with that ticket, at the latest at the end of the export period |
Appendix III - How we secure the data
- Each site sees only its own data, even though sites run on the same servers.
- Confidential fields are stored encrypted on disk.
- Whoever logs in gets only the rights of their role; every change is recorded.
- Traffic to and from the site is encrypted.
- There is a backup every hour, in the Netherlands, and every change to the software first goes through an automated test run.
- We report a data breach to you without undue delay, and at the latest within 48 hours of discovering it.
- Once the customer chat is available, we mask a message on our own servers in the Netherlands before it goes to a language model: email addresses, phone numbers, IBANs, postcode with house number and the names we know of you are replaced with placeholders, which are only restored on our side. Names of others that appear in a message and that we do not know, we cannot recognise this way; that residual risk remains.
- The provider of the language model may not use your data to train a model and may not keep it beyond what is needed to give the answer, as stated in its data processing agreement with us.
Appendix IV - Sub-processors
You give your authorisation for these sub-processors:
| Sub-processor | For what | Where |
|---|---|---|
| Google Cloud | hosting of the servers and receiving email | the Netherlands (region europe-west4) |
| Google Workspace (Google Ireland Limited) | sending email on behalf of your site | Ireland; Google may also process outside the EEA, under the EU standard contractual clauses |
| Google Vertex AI (Google Cloud), with Claude by Anthropic as language model | the customer chat: an answer to a visitor's question, on messages we have masked first | Europe (processing in the European multi-region of Vertex AI), so within the EEA; there is no transfer outside the EEA |
If a sub-processor is added or removed, we notify you at least 30 days in advance. If you do not agree, you may stop.
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