Data processing and deletion

1. Roles and instructions

For personal data in merchant customer records and dispute evidence, the merchant generally acts as controller or business and Zhou Gaili acts as processor or service provider, processing only under the written terms, product settings, and lawful merchant instructions.

2. Processing details

• Subject: Shopify Payments dispute management, evidence preparation, human review, notifications, billing, security, and support.
• Duration: the subscription term plus the limited retention periods in the privacy policy.
• People: merchant team members, buyers, recipients, and people involved in case communications.
• Data: identity and contact data, orders, payments, fulfillment, logistics, refunds, policies, communications, attachments, and technical logs.
• Sensitive scope: merchants are not asked to upload full card numbers, passwords, government IDs, or sensitive data unrelated to a dispute.

3. Security measures

Measures include transport encryption, application-layer encryption for sensitive fields, key separation, tenant isolation, least privilege, RBAC, TOTP, auditing, private object storage, idempotent processing, vulnerability scanning, backups, and incident monitoring.

4. Subprocessors and transfers

Current subprocessors include Shopify, Cloudflare hosting and storage, DeepSeek model services, and Resend transactional email. We will update the list and give reasonable notice where appropriate before enabling another necessary monitoring or support provider. DeepSeek processes minimized model inputs in China and uses default disk context caching that normally lasts from several hours to several days. Where legally required, the parties will use applicable data-transfer terms or another valid mechanism.

5. Requests, incidents, and assistance

We assist with exports, deletion, access controls, audit records, and Shopify mandatory privacy webhooks. After confirming an incident involving merchant data, we notify the merchant without undue delay and provide reasonably available information.

6. Return, deletion, and audits

On termination, personal data is returned or deleted as agreed, except where law requires retention. Merchants should first use the in-app export. Audit rights, evidence method, cost, and confidentiality limits should be finalized in the signed DPA or order form.

7. Processor details

Processor: Zhou Gaili; address: No. 116, Tangbulang Village, Youyouban Town, Huimin District, Hohhot, Inner Mongolia Autonomous Region, China (中国内蒙古自治区呼和浩特市回民区攸攸板镇倘不浪村116号); privacy contact: 776797738@qq.com; governing law: Laws of the People's Republic of China; disputes are subject to the competent courts at the operator's domicile, except where mandatory applicable law provides otherwise / 适用中华人民共和国法律；争议由经营者所在地有管辖权的人民法院处理，但适用的强制性法律另有规定的除外. If applicable law requires standard contractual clauses or a supplemental annex, the parties will complete them before the relevant transfer or processing begins.