Shopify Data Processing Addendum

Last updated on: September 10, 2024

Shopify Data Processing Addendum

I. PURPOSE

This Shopify Data Processing Addendum (“DPA”) supplements and is incorporated by reference into the Shopify Terms of Service, together with any terms applicable to any additional Shopify services that you choose to use (the “Terms”) by and between You (or “Merchant”), and the Shopify Contracting Entity as set forth in the Terms (“Shopify”), which outline the specific business purposes and services related to the DPA. In case of any conflict between the Terms and this DPA, the DPA shall prevail with respect to the processing of Your Personal Data.

Where the processing of Personal Data under the DPA is subject to data protection requirements in the European Economic Area (the “EEA”), the United Kingdom (the “UK”) or Switzerland, Appendix C supplements this DPA. In case of any conflict between Appendix C and other sections of this DPA, Appendix C shall prevail with respect to the processing of Your Personal Data subject to EEA, UK and Swiss privacy requirements.

You and Shopify (each a “Party”, together the “Parties”), agree that this DPA sets forth the Parties’ obligations governing the processing of Your Personal Data in connection with the Terms and Your use of the Services. For the avoidance of doubt, this DPA shall not apply to Shopify’s processing of any Personal Data as a Data Controller, including of Personal Data about Customers that it receives as a result of the Customer’s direct relationship or intentional interaction with Shopify, such as through Shopify’s consumer facing services like Shop and Shop Pay.

II. DEFINITIONS

Capitalized terms used but not defined in this DPA shall have the same meaning given to them in the Terms:

A. Applicable Data Protection Law(s): Any data protection or privacy laws applicable to Shopify’s processing of Your Personal Data under the Terms, their implementing regulations and secondary legislation, each as may be amended, updated or replaced from time to time, including (as applicable, based on the location or residence of Merchant and/or Your Customer(s)):

1. Canada’s Personal Information Protection and Electronic Documents Act 2000 (“PIPEDA”);

2. the (a) California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”), (b) Virginia Consumer Data Protection Act, (c) Colorado Privacy Act, (d) Connecticut Data Privacy Act, (e) Utah Consumer Privacy Act, (f) Oregon Consumer Privacy Act, (g) Texas Data Privacy and Security Act, (h) Montana Consumer Data Privacy Act and (i) once effective, similar comprehensive privacy laws in other U.S. states (together, “U.S. Data Protection Laws”);

3. General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”) and any applicable national implementing laws;

4. EU e-Privacy Directive (Directive 2002/58/EC), as amended (“e-Privacy Law”);

5. UK General Data Protection Regulation (“UK GDPR”) and the UK Data Protection Act 2018 (“UK DPA”);

6. Singapore’s Personal Data Protection Act 2012 (“PDPA”); and

7. Swiss Federal Data Protection Act ("Swiss FDPA")

B. Customer: An individual or entity that visits, engages with, and/or purchases a product, good, or service from Your Store(s).

C. Personal Data: Information or data defined as ‘personal data,’ ‘personal information,’ or ‘personally identifiable information’ (or analogous term) under Applicable Data Protection Laws from or about Your Customers that is made available to Shopify (or third-parties acting on Shopify’s behalf) by You (or third-parties acting on Your behalf) as part of using the Services, as well as other personal data You choose to share with Shopify about Your Customers as part of using the Services. For clarity, Personal Data shall not include any personal data about Customers that Shopify processes as a Data Controller and/or receives as a result of the Customer’s direct relationship or intentional interaction with Shopify or with other Shopify merchants.

D. Data Rights Request: A valid and lawful request by an individual to exercise available rights pertaining to Personal Data under an Applicable Data Protection Law.

E. Data Controller: The Party that determines the purposes and means of the processing of Personal Data, or as otherwise defined under any Applicable Data Protection Law.

F. Data Processor or Service Provider: The Party or other entity or business that provides services on behalf of and processes Personal Data at the direction and on behalf of the Data Controller, and shall be interpreted in accordance with the Applicable Data Protection Laws.

G. Personal Data Breach: In relation to Your Personal Data, shall be interpreted in accordance with Applicable Data Protection Law.

H. “Process,” “processes,” or “processing”: (a) Any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction; or (b) the definition given to such term(s) under the Applicable Data Protection Law.

I. “Subprocessor(s)”: Affiliated companies or third-party Data Processors or Service Providers that may process Personal Data at Shopify’s direction for the purpose of providing the Services.

J. “You,” “Your,” or “Merchant”: Means the business that uses the Services and is a Party to the Terms with Shopify.

III. NATURE OF THE PROCESSING AND ROLES OF THE PARTIES

Shopify receives and processes Your Personal Data in order to provide You with the Services and as otherwise set forth below. Depending on which of the Services You request or use, Shopify will process the categories of Personal Data set forth at Appendix A, in the manner and on the bases contained therein.

Shopify shall only process Your Personal Data as a Data Processor or Service Provider as necessary to provide and improve its Services or as otherwise permitted by Applicable Data Protection Laws. As part of its provision and ongoing improvement of its Services, Shopify may aggregate, anonymize or de-identify Your Personal Data.

To the extent Shopify receives from You Personal Data that has been de-identified, Shopify will maintain and use the data only in a de-identified fashion.

IV. OBLIGATIONS OF PARTIES

The following section describes the Parties’ respective obligations with respect to the processing of Personal Data covered by this DPA.

A. General Compliance

1. The Parties will comply with their respective obligations under Applicable Data Protection Laws.

2. Shopify shall have no obligation to interpret or advise You on Your obligations under Applicable Data Protection Laws, including with respect to Personal Data covered by this DPA. You are solely responsible for determining Your legal and regulatory obligations, including evaluating whether the technical and organizational measures of the Services are consistent with Your independent legal and regulatory obligations.

B. Shopify’s Obligations

1. Data Security
Shopify will implement and maintain appropriate technical and organizational measures designed to protect Your Personal Data against unauthorized or unlawful processing and against accidental loss, destruction, damage, theft, alteration, or disclosure, as set forth in Appendix B.

2. Personal Data Breach Notification and Investigation
a) As required by Applicable Data Protection Laws, Shopify will provide notice to You upon Shopify confirming any Personal Data Breach.

b) Such notice shall include the information required under Applicable Data Protection Laws to the extent such information is reasonably available to Shopify. Shopify’s response to, or notice of, a Personal Data Breach is not an acknowledgment by Shopify of any fault or liability.

c) Shopify agrees to investigate any Personal Data Breach, and use commercially reasonable efforts to identify, prevent, mitigate, and remedy the effects.

3. Data Rights Requests
a) To the extent required under Applicable Data Protection Laws, Shopify will facilitate Your ability to process and respond to Data Rights Requests from Your Customers related to Your use of the Services.

b) To obtain assistance in responding to any such Data Rights Request, forward the Request to Shopify via the Shopify Merchant administrative console/portal, unless Shopify notifies You of a different mechanism.

C. Your Obligations With Respect to Personal Data

1. Privacy Notices and Transparency: You represent and warrant that You are in compliance with all obligations under Applicable Data Protection Laws to provide notice and transparency concerning Your processing of Personal Data under the Terms and in connection with Your use of the Services. To the extent required under Applicable Data Protection Laws, You shall communicate to the relevant individuals all disclosures necessary for Shopify to lawfully and fairly process Personal Data in connection with this DPA, including by providing a link to Shopify’s Privacy Policy or to Your own Privacy Policy.

2. Customer Rights and Permissions: You represent and warrant that You have all necessary rights, permissions, and consents to make available Personal Data to Shopify in accordance with the Terms, Your use of the Services You receive and Applicable Data Protection Laws.

3. Data Rights Requests: You represent and warrant that You provide the ability for Your Customers to exercise Data Rights Requests, as required under Applicable Data Protection Laws, with respect to all Personal Data processed by Shopify for which You are the Data Controller.

4. Regulatory Inquiries: Unless prohibited by applicable law, You will notify us promptly in accordance with the Notice provision in the Terms of any governmental, regulatory or other third party inquiry or complaint concerning Your use of the Services.

V. U.S. DATA PROTECTION LAWS

This section applies only to the extent that: (i) U.S. Data Protection Laws apply to You in connection with Your use of the Services; and (ii) the following provisions are required by U.S. Data Protection Laws and You are a “business” or “controller” under these laws.

A. Shopify will not: (i) retain, use, or disclose such Personal Data outside its direct business relationship with You or for any other purpose other than for the limited and specified purposes identified in this DPA and/or the Terms, including retaining, using or disclosing such Personal Data for a commercial purpose other than for the limited and specified purposes identified in this DPA, and/or the Terms, (ii) "sell" or “share” such Personal Data within the meaning of the CCPA; or (iii) combine such Personal Data with Personal Data that it receives from other sources, in each case except as permitted under U.S. Data Protection Laws.

B. Shopify will (i) provide the same level of privacy protection required of businesses or Data Controllers by such laws, and inform You if it determines that it can no longer meet these obligations, in which case You may take reasonable and appropriate steps to stop or remediate any unauthorized processing of such Personal Data, (ii) ensure personnel who it authorizes to process Personal Data either enter into written confidentiality agreements or are subject to statutory obligations of confidentiality, (iii) upon reasonable written request, and as part of enabling You to take reasonable and appropriate steps to ensure Shopify uses such Personal Data in a manner consistent with U.S. Data Protection Laws, provide the SOC2 report showing a reasonable assessment of Shopify’s information security program; and (iv) upon termination of its Services to You, Shopify will initiate its purge process to delete or de-identify the Personal Data.

C. You represent and warrant that You will not share with Shopify any Personal Data of an individual who has exercised an opt-out right that You have committed to honoring or any sensitive Personal Data of an individual who has not consented to the processing of such sensitive data.

VI. MISCELLANEOUS

A. Global Data Transfers
You acknowledge that Personal Data may be transferred and processed in any country in which Shopify, its affiliated companies or third party service providers are located (including in Singapore and Canada). Any transfer of Personal Data to these recipients will be made in compliance with Applicable Data Protection Laws. For more information on international data transfers, where Shopify is subject to privacy requirements in the EEA, the UK, or Switzerland, see section II(B)(8) of Appendix C.

B. Response to Legal Requests

  1. You acknowledge that, in the course of providing the Services to You, Shopify may share Your Personal Data (i) to comply with legal requirements or to respond to court orders or other similar government or regulatory demands; or (ii) to prevent or investigate suspected fraud, threats to physical safety, illegal activity, or violations of a contract (such as the Terms) or our policies (such as our Acceptable Use Policy).

  2. Shopify will make reasonable efforts before producing such Personal Data to ensure that such disclosure is permitted under Applicable Data Protection Laws and will be treated as confidential information under the applicable legal framework.

C. Disclosure in Corporate Transactions
You acknowledge that, in the course of providing the Services to You, Shopify may be required to share Personal Data with potential counterparties to any corporate or restructuring transaction.

D. Shopify’s Use of Subprocessors/Service Providers

  1. You acknowledge that, in the course of providing the Services to You, Shopify may use Subprocessors to process Personal Data. Shopify maintains an updated list of all Subprocessors used. If Applicable Data Protection Laws grant you such rights, You may object to Shopify’s use of a Subprocessor, and if Shopify is unable or unwilling to accommodate such requests, You may, in accordance with such laws, terminate Your use of the impacted Services within 30 days of such notification in accordance with the Terms.

  2. Shopify’s use of Subprocessors to process Personal Data that You provide will be in compliance with Applicable Data Protection Laws. Where Shopify engages a Subprocessor, Shopify will enter into a written agreement with the Subprocessor that imposes contractual obligations that are substantially the same as the ones set out in this DPA.

E. DPA Amendment
You acknowledge and agree that Shopify may amend this DPA from time to time by posting the relevant amended and restated DPA on Shopify’s website, available at https://shopify.com/legal/dpa and such amendments to the DPA are effective as of the date of posting. Your continued use of the Services after the amended DPA is posted to Shopify’s website constitutes Your agreement to, and acceptance of, the amended DPA. If You do not agree to any changes to the DPA, do not continue to use the Service.

VII Appendices

  1. Appendix A - Categories of Personal Data
  2. Appendix B - Data Security
  3. Appendix C - GDPR, UK GDPR, and Switzerland Data Processing Appendix

APPENDIX A: CATEGORIES OF PERSONAL DATA

As part of Your use of the Services, and depending on which Services You use, we may receive and process the following categories of Personal Data to provide the Services:

  • Customer name, email, contact, billing and shipping information.
  • Purchase and other transaction information from Your Store(s).
  • Update(s) about the status of transaction(s) with You or Your Store(s)
  • Customer activity in Your Store(s), including products viewed and/or included in shopping carts.
  • Customer preference signals, including Global Privacy Control (“GPC”), opt-out and opt-in signals.
  • Customer device information for device(s) used when visiting Your Store(s), including IP address, browser, and network activity.
  • Other information about the Customers’ interactions with You.
  • Any other Personal Data You choose to make available with Shopify.

APPENDIX B: DATA SECURITY

Shopify will maintain an information security program designed to (a) enable You to secure Your Personal Data against unauthorized or unlawful processing and against accidental loss, destruction, damage, theft, alteration, or disclosure; (b) identify reasonably foreseeable risks to the security and availability of the Services You receive; and (c) minimize security risks to the Services.

I. Shopify’s information security program will include the following safeguards:

A. Logical Security

  1. Access Controls Shopify will make its systems accessible only to authorized personnel, and only as necessary to maintain and provide the Services. Shopify will maintain access controls and policies designed to manage authorizations for access to its systems, including through the use of firewalls and/or other technology and authentication controls.

  2. Restricted User Access Shopify will (i) provision and restrict access to its systems in accordance with least privilege principles based on personnel job functions, and (ii) require two-factor authentication (2FA) for access to its systems.

  3. Vulnerability Assessments Shopify will maintain a vulnerability assessment and penetration testing program, responsible for investigating and tracking identified issues with the Services to resolution where necessary.

  4. Application Security Shopify maintains an application security program responsible for protecting Services from application security threats.

  5. Change Management Shopify will maintain controls designed to log, authorize, test, approve and document changes to existing Services resources, and will document change details within its change management or deployment tools. Shopify will test changes according to its change management standards prior to migration to production.

  6. Data Integrity As appropriate, Shopify will maintain controls designed to provide data integrity during transmission, storage and processing within the Services.

  7. Availability Shopify will (i) implement redundancy where appropriate for the Services to minimize the effect of a malfunction on the Services, (ii) design the Services to anticipate and tolerate failures, and (iii) implement appropriate processes designed to move Personal Data traffic away from the affected areas when necessary to recover from failures.

  8. Business Continuity and Disaster Recovery Shopify will maintain a risk management program designed to support the continuity of its critical business functions, including processes and procedures for identification of, response to, and recovery from, events that could prevent or materially impair Shopify’s provision of the Services You receive.

  9. Incident Management Shopify provides documentation for You to report security or availability incidents, ask security or availability questions, and submit information about potential security or availability issues. Shopify will maintain corrective action plans and incident response plans designed to detect, mitigate, investigate, and respond to potential security threats to the Services.

B. Physical Security Where necessary to protect Services, Shopify will (i) implement reasonable measures designed to prevent unauthorized physical access, damage, or interference to the Services, (ii) use appropriate control devices designed to restrict physical access to the Services to only authorized personnel who have a legitimate business need for such access, and (iii) perform periodic reviews to validate adherence with these standards.

C. Shopify Employees Shopify employees who are authorized to access Personal Data are bound by obligations of confidentiality as part of their terms of employment. Shopify will implement and maintain employee security training programs regarding Shopify information security requirements. The security awareness training programs will be reviewed and updated periodically.

II. Modifications to this Appendix

Shopify reviews its security measures from time to time, and may update this Appendix in its sole discretion. Any such updates will replace prior versions of this Appendix as of the date that Shopify publishes the updated version.

APPENDIX C: GDPR, UK GDPR, AND SWITZERLAND DATA PROCESSING APPENDIX

Where the processing of Personal Data under the DPA is subject to data protection requirements in the European Economic Area (the “EEA”), the United Kingdom (the “UK”), or Switzerland (collectively, “European Data Protection Laws”), Appendix C supplements this DPA.

I. Nature of the Processing and Role of the Parties

A. Personal Data

  1. Under this Appendix You shall act as a Data Controller and Shopify shall act as a Data Processor with respect to the processing of Your Personal Data as described in Annex 1, as necessary to fulfill the business purposes outlined in the Terms and provide You with the Services You choose to use.
  2. For the avoidance of doubt, Shopify shall act as an independent Data Controller with respect to Personal Data about Customers that Shopify receives as a result of the Customer’s direct relationship or intentional interactions with Shopify, as described in Shopify’s Privacy Policy.

II. Obligations of the Parties

A. Your Obligations

You shall comply with:

  • European Data Protection Laws binding on You in the performance of this Appendix; and
  • Your obligations set out in the DPA, including Your obligations set forth in this Appendix.

You represent and warrant that You have a valid legal basis for processing the Personal Data (including making any such data available to Shopify) and have obtained any necessary consents, rights and authorizations and given any necessary notices to individuals regarding Your disclosure of Personal Data to Shopify to enable Shopify’s processing of Personal Data to provide the Services, as required by European Data Protection Laws.

B. Shopify’s Obligations

1. Instructions of the Controller and Infringement of European Data Protection Laws

a) The Parties agree that the Terms together with this DPA constitute Your documented instructions regarding Shopify’s processing of Your Personal Data (“Documented instructions”).

b) Shopify will process Personal Data as a Processor only: (i) in accordance with Your Documented instructions, or (ii) to comply with Shopify's obligations under applicable laws, subject to any notice requirements under European Union or European Union member state law to which Shopify is subject.

c) Shopify will notify You if it receives an instruction that it reasonably determines infringes European Data Protection Laws (but Shopify has no obligation to actively monitor Your compliance with European Data Protection Laws).

2. Confidentiality obligation

Shopify will ensure persons who it authorizes to process Personal Data either enter into written confidentiality agreements or are subject to statutory obligations of confidentiality.

3. Security measures

a) Shopify shall implement and maintain appropriate technical and organizational measures designed to protect Your Personal Data against unauthorized or unlawful processing and against accidental loss, destruction, damage, theft, unauthorized access, alteration, or disclosure, as set forth in Annex 2.

b) Taking into account the nature of the Personal Data and related processing, Shopify shall provide such reasonable assistance as You may reasonably request to help You fulfill Your security obligations under European Data Protection Laws.

c) Shopify shall provide You with notice, without undue delay, upon becoming aware of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Your Personal Data transmitted, stored or otherwise processed.

d) Shopify agrees to investigate any such security breach and use commercially reasonable efforts to mitigate the effects.

4. Subprocessors

a) You generally authorize Shopify to engage Subprocessors to process Personal Data. You further agree that Shopify may engage its affiliates as Subprocessors.

b) Shopify’s use of Subprocessors to process Your Personal Data will be in compliance with European Data Protection Laws.

c) Shopify maintains an updated list of all Subprocessors as set forth in Annex 3. Shopify will update the list of Subprocessors as appropriate and provide You with a mechanism to obtain notice of the addition or replacement of a Subprocessor. You may object to Shopify’s use of a new Subprocessor.

d) To the extent You object to Shopify’s use of a Subprocessor, and Shopify is unable or unwilling to accommodate such requests, You may terminate Your use of the impacted Services within 30 days of such notification in accordance with the Terms.

e) Where Shopify engages a new Subprocessor, Shopify will enter into a written agreement with the Subprocessor and Shopify will impose, on the Subprocessor, contractual obligations that are substantially the same as the ones set out in this DPA. Shopify shall be fully liable for the acts and omissions of its Subprocessors to the same extent Shopify would be liable if performing the services of each Subprocessor directly under the terms of this DPA. Shopify’s liability will nevertheless be subject to the conditions and limitation of liability set forth in the Terms.

5. Assistance to the Controller
Taking into account the nature of Your Personal Data and related processing, Shopify shall provide such reasonable assistance as You may reasonably request to assist You in complying with Your obligations:

  • to respond to Data Rights Requests under European Data Protection Laws;
  • to notify relevant authorities and/or data subjects of a Personal Data Breach;
  • to conduct data protection impact assessments and prior consultations;
  • to ensure the security of the processing in accordance with section 3.

6. Assessing compliance

a) Shopify may fulfill Your right of audit under European Data Protection Laws in relation to the processing of personal data by providing You - upon Your written request and subject to confidentiality - with:

(i) Shopify's most recent audit report results, either from Shopify's self-audits or prepared by an independent third party auditor;
(ii) additional information in Shopify's control if a data protection or governmental authority requests it.

b) Provided that and only to the extent that European Data Protection Laws grant You this right, You may exercise Your Audit right: (i) to the extent that an independent internationally recognized auditor attests that Shopify's provision of an audit report does not provide sufficient information for You to verify Shopify's compliance with this DPA and with European Data Protection Laws or (ii) as necessary for You to respond to a government authority audit. Each audit must conform to the following parameters: (i) be conducted by an independent third party that will enter into a confidentiality agreement with Shopify; (ii) be limited in scope to matters reasonably required, and as mutually agreed upon, for You to assess Shopify's compliance with this DPA and the parties’ compliance with European Data Protection Laws; (iii) occur at a mutually agreed date and time and only during Shopify's regular business hours; (iv) occur no more than once annually (unless required under European Data Protection Laws); (v) cover only facilities controlled by Shopify; (vi) restrict findings to Personal Data only; and (vii) treat any results as confidential information to the fullest extent permitted by European Data Protection Laws. For clarification, Shopify will comply with any of Your rights under this section 6 in accordance with its confidentiality obligations with third parties.

7. End of processing

a) During Your use of the Services, You may leverage account tools to access, return to yourself, or delete Personal Data.

b) Following termination, Shopify will, at Your choice, delete or return Your Personal Data. Notwithstanding the foregoing, Shopify may retain Personal Data: (i) as required by law, including European Data Protection Laws; and (ii) in accordance with its standard backup or record retention policies, provided that, in either case, Shopify will maintain the confidentiality of, and otherwise comply with the applicable provisions of this DPA with respect to, retained Personal Data, and not further Process retained Personal Data except for such purpose(s) and duration permitted under such applicable laws.

8. International Transfers

a) Subject to compliance with European Data Protection Laws, Shopify International Ltd. may transfer Personal Data processed under this Appendix outside of the EEA, the UK, and Switzerland as necessary to provide its Services (“International Transfers”).

b) Such transfers consist primarily in transferring Personal Data to Shopify Inc., based in Canada which benefits from a decision of the EU Commission 2002/2/EC dated December 20, 2001 on the adequate protection of personal data provided by the Canadian Personal Information Protection and Electronic Documents Act.

c) Any International Transfers to countries which do not ensure an adequate level of data protection within the meaning of the European Data Protection Laws, will be subject to appropriate safeguards including the following transfer mechanisms:

  • the relevant modules under the 2021 Standard Contractual Clauses approved by the European Commission in its decision 2021/914/EC dated June 4, 2021;
  • the International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers issued by the UK Information Commissioner’s Office under S119A(1) of the UK Data Protection Act 2018;
  • the 2021 Standard Contractual Clauses as amended to satisfy the requirements of the Swiss Federal Act on Data Protection (as amended from time to time) of June 19, 1992 as revised as of September 25, 2001; and
  • any standard contractual clauses, international data transfer addendum or other clauses, addenda or transfer mechanisms that might replace the current clauses and addendum.

d) Shopify may, in its sole discretion, replace any transfer mechanism to ensure that data transfers comply with applicable laws. If a transfer is based on standard contractual clauses and such clauses are updated by the relevant authorities, such updated clauses or similar agreements will be incorporated into this DPA as if fully stated herein.

ANNEX 1 - PERSONAL DATA

DESCRIPTION OF THE PROCESSING OF PERSONAL DATA

I. Subject Matter of the Processing

Provision of Shopify Services to Merchant.

II. Categories Of Data Subjects

Customers of Merchant.

III. Categories Of Personal Data Processed

See Appendix A above.

IV. Frequency of the transfer

Continuous.

V. Nature Of The Processing

Collection, recording, hosting, access, use, transfer and deletion of Personal Data as described in the Terms.

VI. Purposes For Which The Personal Data Is Processed On Behalf Of The Controller

For the performance and improvement of the Services as described in the Terms.

VII. Duration Of The Processing

Duration of the Services under the Terms or applicable agreement, plus the period after such expiration until the anonymization, return, or deletion of data.

VIII. Competent Supervisory Authority The competent supervisory authority will be the Data Protection Commission of Ireland.

ANNEX 2 - SECURITY MEASURES

Information on security measures is provided in Appendix B of the DPA.

ANNEX 3 - LIST OF SUBPROCESSORS

The Subprocessors used by Shopify for the performance of the Services under the Terms are listed here.

The Subprocessors will process the categories of Personal Data described above in connection with the Services for the duration of their agreement with Shopify.