Data Processing Agreement

Roles

You are the data controller for your customers' personal data. CubieFlow is the processor. We process that data only on your documented instructions — using the product is an instruction — and for no purpose of our own.

This DPA is incorporated into the Terms of Service automatically. You do not need to sign a separate copy, though we will countersign one if your procurement process requires it.

Scope of processing

What we process, and why.

• Categories of data: contact details, order history, delivery addresses, payment metadata, message content and consent records.
• Categories of subject: your customers, and your own team members.
• Purpose: providing the CubieFlow service — syncing, storing, presenting and transmitting the data as the product requires.
• Duration: for as long as your workspace is active, plus the deletion window in the Privacy Policy.

Our obligations

The commitments that matter most in practice:

• Process only on your instructions, and tell you if an instruction appears to breach applicable law.
• Keep the data confidential and bind every person with access to confidentiality.
• Apply appropriate technical and organisational measures — encryption in transit and at rest, least-privilege access, audit logging.
• Help you respond to data subject requests, and to regulators, within the statutory timeframes.
• Notify you of a personal data breach without undue delay, and within 72 hours of becoming aware.
• Delete or return the data at the end of the agreement, at your choice.

Subprocessors

We use subprocessors for infrastructure, payment processing, email delivery and error monitoring. Each is contractually bound to terms no weaker than these.

The current list is published and versioned. We give 30 days' notice before adding one, and you can object. If we cannot resolve an objection, you may terminate the affected service without penalty — including a refund of anything prepaid.

International transfers

Your commerce data stays in the region you selected. Where a subprocessor operates outside that region, transfers rely on Standard Contractual Clauses and a documented transfer impact assessment.

If you need data residency guaranteed with no cross-border transfer at all, that is an Enterprise arrangement — talk to us before signing up rather than after.

Audit

You may audit our compliance with this DPA once per year, or after a breach affecting your data. In most cases our security documentation and third-party reports will answer your questions; where they do not, we will accommodate a reasonable audit at your cost.

Support access

CubieFlow support can only enter your workspace with a recorded reason and a time limit, and the access expires automatically. It is read-only unless you explicitly grant write access. Every such session appears in your audit log, which you can read at any time — you should not have to take our word for it.