Data Processing Agreement

For data we retrieve from a platform you connect, you are the controller and we are your processor. We process it only on your documented instructions, which are these terms and the settings you choose in Pullsy. If we are ever required by law to process it otherwise, we will tell you first unless the law forbids it.

Your own account details (your name, email and billing information) are not covered here: for those we are the controller, as the Privacy Policy explains.

We process connected-platform data for one purpose: to show you, and give you API access to, analytics about your own business. We do not sell it, use it for advertising, combine it across customers, or use it to train machine-learning models.

Only personnel who need access to run the service have it, and they are bound by confidentiality. Each request to Pullsy is scoped to a single workspace, so one customer cannot reach another’s data, and every view of a store’s data, in the dashboard or through the API, is recorded in an access log kept for 24 months.

• All data is encrypted in transit (TLS) and at rest, including backups.
• Platform access tokens are additionally encrypted with keys we can rotate.
• Test and development data are kept separate from production.
• Webhooks from connected platforms are rejected unless their signature verifies.
• Credentials and tokens are redacted from logs.

The full list is in section 8 of the Privacy Policy. We may improve these measures over time but will not reduce the overall level of protection.

You authorise us to use sub-processors for hosting, database, storage, email and payments, in the categories listed in the Privacy Policy. Each is bound by written terms at least as protective as these. The named list is available on request from legal@getpullsy.com. We will tell you before adding or replacing a sub-processor, and you may object; if we cannot reasonably accommodate the objection, you may terminate and we will refund the unused part of your current period.

If one of your customers asks you to access, correct or delete their data, we will help you answer. For Shopify, we act on Shopify’s own privacy requests automatically: a customer data request or deletion request finds nothing to return or erase, because we hold no customer identities, and a store deletion request erases that store’s data.

We will also give you the information you reasonably need to show compliance with this agreement, including answers to security questionnaires.

If we become aware of a breach affecting personal data we process for you, we will notify you without undue delay and within 72 hours, with what we know about its nature, the data affected, its likely consequences and what we are doing about it, and we will keep you updated as we learn more.

When you disconnect a platform, its data stops being shown or served immediately and is deleted 30 days later; if the platform stops accepting our access, it is deleted after 90 days. Uninstalling Pullsy from a Shopify store disconnects it at once, and Shopify’s store deletion request, which follows 48 hours later, erases the store’s data. Deleting your workspace deletes all of it. Full retention periods are in section 7 of the Privacy Policy.

Our infrastructure runs in the United States. For personal data from the EEA and the UK we rely on the European Commission’s Standard Contractual Clauses and the UK International Data Transfer Addendum, as section 6 of the Privacy Policy describes.