Data Processing Addendum

Last updated 15 October 2026

1. Background and application

1.1 This Data Processing Addendum (the Addendum) forms part of the Seilfi Terms of Service (the Terms) between Hygge Tygge Ventures Limited, an Irish company (company number 822196) with its registered office at The Studio, Upper Cliff Road, Howth, Co. Dublin, Ireland (Seilfi, we or us) and the merchant that installs the App (the Merchant or you).

1.2 This Addendum applies to the extent that Seilfi processes Personal Data on behalf of the Merchant in providing the App. It sets out the terms required by Article 28(3) of the GDPR.

1.3 This Addendum does not apply to Personal Data that Seilfi processes as a controller for its own purposes, such as the Merchant's account and subscription details, support correspondence and security logs. Seilfi's processing of that data is described in the Seilfi Privacy Notice.

1.4 The Merchant accepts this Addendum by installing the App or by otherwise accepting the Terms. Where the person accepting does so on behalf of the Merchant, that person confirms that they have authority to bind the Merchant.

2. Definitions and interpretation

2.1 Capitalised terms not defined in this Addendum have the meanings given in the Terms. In this Addendum:

App means the Seilfi application distributed through the Shopify App Store, as described in the Terms.
Data Protection Law means the GDPR, the Data Protection Act 2018 (Ireland), the European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011 and any other law of Ireland or the European Union that applies to the processing of Personal Data under this Addendum, each as amended or replaced from time to time.
GDPR means Regulation (EU) 2016/679.
Merchant Personal Data means Personal Data contained in Merchant Data that Seilfi processes on behalf of the Merchant in providing the App, as described in Schedule 1.
Personal Data, controller, processor, data subject, processing, personal data breach and supervisory authority have the meanings given in the GDPR.
Restricted Transfer means a transfer of Merchant Personal Data to a country outside the European Economic Area that is not the subject of an adequacy decision of the European Commission under Article 45 GDPR.
Security Measures means the technical and organisational measures described in Schedule 2.
Standard Contractual Clauses means the standard contractual clauses for the transfer of personal data to third countries adopted by the European Commission in Implementing Decision (EU) 2021/914, as amended or replaced from time to time.
Sub-processor means any third party engaged by Seilfi to process Merchant Personal Data.

2.2 If there is any conflict between this Addendum and the Terms in relation to the processing of Personal Data, this Addendum prevails. If there is any conflict between this Addendum and the Standard Contractual Clauses in relation to a Restricted Transfer, the Standard Contractual Clauses prevail.

3. Roles of the parties

3.1 The parties acknowledge that, in respect of Merchant Personal Data, the Merchant is the controller and Seilfi is the processor.

3.2 The Merchant is responsible for ensuring that it has a lawful basis for the processing of Merchant Personal Data by Seilfi under this Addendum, and that its instructions to Seilfi comply with Data Protection Law. In particular the Merchant shall:

(a) provide its staff whose names, comments and email addresses are entered into the App with the information required by Articles 13 and 14 GDPR. A short form of wording that the Merchant may use is set out in Schedule 4;

(b) configure the App, including the recipients of reports and alerts, in accordance with Data Protection Law; and

(c) not enter into the App, or instruct Seilfi to process, any special category data within Article 9 GDPR, any data relating to criminal convictions, or any payment card data.

3.3 The Merchant acknowledges that the App is designed to operate without the personal data of the Merchant's customers, that Seilfi does not request access to customer records from Shopify, and that pick lists show only the order number, the items and their bin location. Where the Merchant nonetheless enters customer personal data into a free-text field of the App, the Merchant does so as controller and on its own responsibility.

4. Processing on instructions

4.1 Seilfi shall process Merchant Personal Data only on the documented instructions of the Merchant, including with regard to Restricted Transfers, unless required to do otherwise by European Union or Irish law to which Seilfi is subject. In that case Seilfi shall inform the Merchant of the legal requirement before processing, unless that law prohibits it from doing so on important grounds of public interest.

4.2 The Merchant's documented instructions are the Terms, this Addendum (including Schedule 1), and the Merchant's configuration and use of the App, including the features it enables, the locations and products it manages and the report recipients it selects. Additional instructions must be agreed in writing and may be subject to additional fees.

4.3 Seilfi shall inform the Merchant without delay if, in Seilfi's opinion, an instruction infringes Data Protection Law. Seilfi is not obliged to carry out a legal review of the Merchant's instructions.

4.4 Seilfi shall not sell Merchant Personal Data, share it with any third party for that third party's own purposes, use it for advertising, or use it to train machine learning or artificial intelligence models.

5. Confidentiality

5.1 Seilfi shall ensure that every person it authorises to process Merchant Personal Data is bound by a contractual or statutory duty of confidentiality, and processes Merchant Personal Data only as necessary to provide the App.

5.2 Seilfi shall limit access to Merchant Personal Data to those personnel who need it to provide, support or secure the App.

6. Security

6.1 Taking into account the state of the art, the costs of implementation, and the nature, scope, context and purposes of the processing, as well as the risk to the rights and freedoms of data subjects, Seilfi shall implement and maintain the Security Measures and such other technical and organisational measures as are appropriate to ensure a level of security appropriate to the risk, in accordance with Article 32 GDPR.

6.2 Seilfi may update the Security Measures from time to time provided that the updates do not materially reduce the overall level of protection of Merchant Personal Data.

6.3 The Merchant is responsible for the security of its own systems and for the passcodes it sets for each location. The Merchant shall keep passcodes confidential and shall change them if it believes they have been compromised.

7. Sub-processors

7.1 The Merchant gives Seilfi general written authorisation to engage Sub-processors to process Merchant Personal Data, subject to this clause 7. The Merchant authorises the Sub-processors listed in Schedule 3 as at the date of this Addendum.

7.2 Seilfi shall publish its current list of Sub-processors at my.seilfi.com/subprocessors and shall provide a means by which the Merchant can subscribe to notice of changes to that list.

7.3 Seilfi shall give the Merchant at least 10 days' prior notice of the addition or replacement of a Sub-processor by updating the published list and, where the Merchant has subscribed, by email.

7.4 If the Merchant has a reasonable objection on data protection grounds to a new Sub-processor, the Merchant may notify Seilfi in writing within the notice period, giving reasons. The parties shall discuss the objection in good faith. If Seilfi cannot reasonably accommodate the objection, the Merchant may terminate the Terms by uninstalling the App before the new Sub-processor begins processing Merchant Personal Data. This is the Merchant's sole remedy for an objection to a Sub-processor.

7.5 Where Seilfi engages a Sub-processor, Seilfi shall enter into a written contract with the Sub-processor that imposes data protection obligations that offer at least the same level of protection for Merchant Personal Data as those set out in this Addendum, in accordance with Article 28(4) GDPR. Seilfi remains fully liable to the Merchant for the performance of the Sub-processor's obligations.

8. International transfers

8.1 Seilfi is established in Ireland. The App runs in, and its database is located in, data centres in Dublin, Ireland, as described in Schedule 3.

8.2 The Merchant acknowledges that each Sub-processor listed in Schedule 3 is a company established in the United States, and that a Restricted Transfer may occur where a Sub-processor stores backups or logs outside the European Economic Area, provides support from outside the European Economic Area, or, in the case of the email provider, stores message content and delivery logs in the United States.

8.3 Seilfi shall not make or permit a Restricted Transfer unless it has first ensured that the transfer is covered by an appropriate safeguard under Chapter V GDPR. As at the date of this Addendum, Seilfi relies on the Standard Contractual Clauses (Module Three, processor to processor) incorporated into its contract with each Sub-processor and, where the Sub-processor is certified under the EU-US Data Privacy Framework, on that certification as an additional basis. Seilfi shall provide the Merchant with a copy of the relevant clauses on request.

8.4 Seilfi shall keep the transfer arrangements under review and shall put in place an alternative safeguard if any safeguard relied on ceases to be valid. Seilfi shall, taking into account the nature of the processing and the information available to it, assist the Merchant in documenting any assessment of a Restricted Transfer that the Merchant is required to carry out.

8.5 The Merchant instructs and authorises Seilfi to make the Restricted Transfers described in this clause 8 and in Schedule 3.

8.6 Merchants established in the United Kingdom. Where the Merchant is established in the United Kingdom: (a) references in this Addendum to the GDPR include the UK GDPR (Regulation (EU) 2016/679 as it forms part of the law of the United Kingdom by virtue of section 3 of the European Union (Withdrawal) Act 2018) and the Data Protection Act 2018 (UK), and references to Article 28 include Article 28 UK GDPR; (b) the Merchant's transfer of Merchant Personal Data to Seilfi in Ireland is made under the UK's adequacy regulations for the European Economic Area; (c) references to a supervisory authority include the Information Commissioner; and (d) Seilfi shall ensure that any onward Restricted Transfer of UK Merchant Personal Data to a Sub-processor is covered by the Standard Contractual Clauses as amended by the International Data Transfer Addendum issued by the Information Commissioner under section 119A of the Data Protection Act 2018 (UK), or by the UK Extension to the EU-US Data Privacy Framework, or by another mechanism valid under UK law. As at the date of this Addendum each Sub-processor's contract with Seilfi incorporates the UK Addendum.

8.7 Merchants established in Switzerland. Where the Merchant is established in Switzerland: (a) references to the GDPR include the Swiss Federal Act on Data Protection of 25 September 2020 (the FADP) to the extent it applies; (b) the Merchant's transfer of Merchant Personal Data to Seilfi in Ireland is made to a country recognised by the Swiss Federal Council as providing adequate protection; (c) references to a supervisory authority include the Federal Data Protection and Information Commissioner; and (d) Seilfi shall ensure that any onward Restricted Transfer of Swiss Merchant Personal Data is covered by the Standard Contractual Clauses with the modifications required by the Federal Data Protection and Information Commissioner, or by the Swiss-US Data Privacy Framework, or by another mechanism valid under Swiss law.

9. Assistance with data subject rights

9.1 Taking into account the nature of the processing, Seilfi shall assist the Merchant by appropriate technical and organisational measures, insofar as this is possible, in fulfilling the Merchant's obligation to respond to requests from data subjects exercising their rights under Chapter III GDPR.

9.2 The App enables the Merchant to view and, where the App provides for it, correct or delete audit and stock-take records, report recipients and settings. Where a request cannot be fulfilled through the App, the Merchant may ask Seilfi for assistance and Seilfi shall respond within 20 business days.

9.3 If Seilfi receives a request from a data subject relating to Merchant Personal Data, Seilfi shall not respond to it except to direct the data subject to the Merchant, and shall notify the Merchant of the request without undue delay.

9.4 Requests received from Shopify under its mandatory privacy webhooks (customer data request, customer redact and shop redact) are handled in accordance with Schedule 1, paragraph 8, and clause 12.

10. Personal data breaches

10.1 Seilfi shall notify the Merchant without undue delay, and in any event within 48 hours, after becoming aware of a personal data breach affecting Merchant Personal Data.

10.2 The notification shall, so far as the information is available to Seilfi, describe the nature of the breach, the categories and approximate number of data subjects and records concerned, the likely consequences, the measures taken or proposed to address the breach, and a contact point. Seilfi may provide the information in phases as it becomes available.

10.3 Seilfi shall take reasonable steps to contain and mitigate the breach and shall provide the Merchant with reasonable assistance in meeting the Merchant's obligations under Articles 33 and 34 GDPR.

10.4 Seilfi's notification of a breach is not an admission of fault or liability.

11. Impact assessments and prior consultation

11.1 Taking into account the nature of the processing and the information available to Seilfi, Seilfi shall provide reasonable assistance to the Merchant with any data protection impact assessment and any prior consultation with a supervisory authority that the Merchant is required to carry out in relation to the processing of Merchant Personal Data by the App.

11.2 Seilfi may charge its reasonable costs for assistance under this clause 11 and clause 9 where the assistance requires significant resources, except where the need for assistance arises from Seilfi's breach of this Addendum.

12. Deletion and return

12.1 The Merchant may at any time while the App is installed download its stock valuation, purchase order and business overview reports from the App in CSV format. The Merchant's product and stock data remain in its own Shopify store. In addition, on written request made before or within 10 business days after uninstallation, Seilfi shall provide the Merchant with a copy of its audit and stock-take records held by the App, in a commonly used electronic format, within 20 business days of the request.

12.2 When the Merchant uninstalls the App, Seilfi shall delete the Merchant's Shopify access token immediately.

12.3 Shopify sends Seilfi a shop redact request 48 hours after uninstallation. On receipt of that request, and in any event within 10 days of uninstallation (or, where the Merchant has made a request under clause 12.1, within 10 days after Seilfi has provided the copy), Seilfi shall delete all Merchant Personal Data, including staff passcode records and settings, except to the extent that European Union or Irish law requires Seilfi to retain it. Seilfi shall confirm deletion on request.

12.4 Merchant Personal Data may persist in a Sub-processor's backups for a limited period after deletion. Seilfi shall ensure that such data is deleted in accordance with the Sub-processor's scheduled backup deletion routines, which as at the date of this Addendum do not exceed 28 days for the database provider and 7 days for the email provider, and is put beyond use in the meantime.

12.5 Seilfi may retain a record that the shop redact request was received and handled, containing only the request type, the store identifier and the identifiers Shopify supplied, for the purpose of demonstrating compliance.

13. Information and audit

13.1 Seilfi shall make available to the Merchant all information necessary to demonstrate compliance with Article 28 GDPR. Seilfi shall satisfy this obligation in the first instance by providing, on written request no more than once in any 12-month period: this Addendum and its Schedules; the current Sub-processor list; a summary of the Security Measures; and copies of, or extracts from, the most recent third-party audit reports or certifications (such as SOC 2 Type II) that its Sub-processors make available to Seilfi, subject to the confidentiality terms on which they are provided.

13.2 If the Merchant reasonably considers that the information provided under clause 13.1 is not sufficient to demonstrate compliance, or a supervisory authority requires it, the Merchant or an independent auditor appointed by the Merchant and reasonably acceptable to Seilfi may audit Seilfi's processing of Merchant Personal Data, on at least 30 days' written notice, during business hours, no more than once in any 12-month period (except following a personal data breach), in a manner that does not unreasonably disrupt Seilfi's business, and subject to the auditor entering into a confidentiality agreement.

13.3 The Merchant shall bear the costs of any audit under clause 13.2 unless the audit reveals a material breach of this Addendum by Seilfi. Seilfi is not obliged to give the Merchant access to the premises or systems of a Sub-processor; Seilfi shall instead exercise its own audit and information rights against the Sub-processor on the Merchant's reasonable request.

14. Liability

14.1 Each party's liability arising out of or in connection with this Addendum, including liability under Article 82 GDPR as between the parties, is subject to the exclusions and limitations of liability in the Terms. The cap in the Terms applies to the parties' aggregate liability under the Terms and this Addendum together, and not separately to each.

14.2 Nothing in this Addendum limits either party's liability to a data subject, or the rights of a data subject as a third-party beneficiary under the Standard Contractual Clauses.

14.3 Where both parties are responsible for damage caused by processing that infringes the GDPR, each party is liable to the other only for the part of the damage that corresponds to its responsibility, in accordance with Article 82(5) GDPR.

15. Term and general

15.1 This Addendum takes effect when the Merchant accepts the Terms and continues until Seilfi has deleted all Merchant Personal Data in accordance with clause 12.

15.2 Seilfi may amend this Addendum on 30 days' notice to the Merchant where the amendment is required by a change in Data Protection Law, a change in guidance of a supervisory authority or the European Data Protection Board, or a change in Shopify's requirements, provided that the amendment does not materially reduce the protection of Merchant Personal Data. Other amendments require the Merchant's agreement, which may be given by continuing to use the App after notice.

15.3 This Addendum is governed by the laws of Ireland and the parties submit to the exclusive jurisdiction of the courts of Ireland, without prejudice to the governing law and forum provisions of the Standard Contractual Clauses.

Schedule 1: Details of processing


Subject matter	The provision of the Seilfi inventory application to the Merchant through the Shopify App Store, including counting stock by weight, stock audits, stock takes, live stock levels by location, reports, alerts, reorder forecasting, stock transfers between locations, goods-in and receiving, purchase orders and order picking.
Duration	From installation of the App until deletion of Merchant Personal Data under clause 12.
Nature of processing	Collection from Shopify and from the Merchant's staff; storage; organisation; retrieval; use to produce counts, audits, reports, alerts, forecasts, pick lists, transfer plans and purchase orders; writing of stock levels, transfers and fulfilments to the Merchant's Shopify store; transmission by email to recipients chosen by the Merchant; and deletion.
Purpose	To provide the App to the Merchant in accordance with the Terms and the Merchant's configuration of the App.
Categories of data subjects	(a) The Merchant's staff and other authorised users of the App. (b) The Merchant's personnel who are designated to receive reports and alerts. (c) Where the Merchant is a sole trader or the store details identify an individual, the Merchant. (d) The Merchant's customers, only to the extent that Shopify privacy webhooks identify them by identifier; no customer contact details are processed.
Categories of Personal Data	(a) Staff name entered at sign-in. (b) Names of auditors and stock-take submitters and their free-text comments. (c) Email addresses of report and alert recipients; the Merchant's reply-to address and business name. (d) Store details: shop name, Shopify domain, currency, Shopify plan and locations. (e) Order data limited to order number, date, totals, refunds, shipping price, sales channel, location and line items, read to calculate sales velocity (only aggregated per-product sales counts are stored) and to produce pick lists showing order number, items and bin location only. (f) Identifiers contained in Shopify privacy webhook requests. Fulfilment orders and store-to-store transfers are read live from the Merchant's Shopify store and are not stored by Seilfi. Purchase orders, goods-in records and the weekly transfer plan are stored for the periods set out in this Schedule. Purchase orders contain the supplier name from the product's vendor field, products, SKUs, barcodes and quantities, and no contact details. The weekly transfer plan (products, stores, quantities, timestamps) contains no Personal Data. Product, variant, stock and cost data are business data and are not Personal Data except where they identify an individual.
Special category data	None. The Merchant shall not enter special category data or data relating to criminal convictions into the App.
Shopify permissions	Thirteen: read and write products; read and write inventory; read locations; read orders and read orders older than 60 days; read and write inventory transfers; read and write merchant-managed fulfilment orders; read and write fulfilments. No access to customer records is requested. Level 1 access under Shopify's protected customer data programme.
Retention	Signed-in session: 12 hours (store staff) or 7 days (head office). Audit sessions and results: 90 to 120 days; audit flags 180 days; daily scores 8 days. Stock-take sessions: 90 days; weight error records 180 days. Minimum and maximum forecasts: 90 days. Overrides and weight maps: 365 days. Stock-level snapshots: 400 days. Merchant settings and Shopify access token: while installed, then deleted under clause 12. Weekly transfer plan: 90 days, and deleted in full on uninstallation. Pick lists and store-to-store transfers: not stored, read live from the Merchant's Shopify store. Purchase orders: the current draft order 60 days; the purchase order history record (supplier name taken from the product's vendor field in Shopify, status, dates and quantities) 2 years; goods-in and delivery records 1 year. Shopify privacy request logs: request type, store and identifiers only, kept 6 years; on shop redact the record is reduced to request type, store, date and action taken, with no customer or order identifiers.
Shopify privacy webhooks (paragraph 8)	Seilfi subscribes to the customers/data_request, customers/redact and shop/redact topics. Each request is verified by HMAC signature and rejected if verification fails. Receipt is acknowledged to Shopify. Customer data requests and customer redact requests are logged; as the App stores no customer personal data, no further action is required. Shop redact requests result in deletion of all data for the store as described in clause 12. Each request is actioned within 30 days of receipt, as Shopify requires.

Schedule 2: Technical and organisational measures

Seilfi maintains the following measures. Measures marked with an asterisk are provided by, and described in the published security documentation of, the Sub-processor named.

Access control and authentication

Access to the App by the Merchant's staff is controlled by per-location passcodes set by the Merchant. Passcodes are stored only as salted PBKDF2 hashes.
Access by account holders is controlled by an email address and password. Passwords are stored only as salted scrypt hashes, with parameters chosen to make large-scale cracking expensive, and cannot be read or recovered by Seilfi. Authentication answers identically, and takes the same time, whether the password is wrong or the address is unknown, so the sign-in form cannot be used to discover who holds an account.
Sessions are cryptographically signed and expire after 12 hours (store staff) or 7 days (head office).
Administrative and scheduled functions require a secret key held only by Seilfi.
Every request from Shopify, including installation requests and privacy webhooks, is verified by HMAC signature and rejected if verification fails.
Seilfi personnel access to production systems is limited to named individuals with a need to know and is protected by multi-factor authentication.
*Vercel, Neon and Upstash apply role-based access controls and least-privilege principles to their own personnel.

Encryption and pseudonymisation

All traffic between the Merchant's browser, Shopify, the App and Seilfi's Sub-processors is encrypted in transit using TLS.
Shopify access tokens are encrypted by Seilfi before storage, in addition to any encryption at rest provided by the database provider.
*Vercel encrypts data at rest using AES-256. *Neon encrypts data at rest through the cloud provider. *Upstash provides AES-256 encryption at rest through the cloud provider. *Resend encrypts data at rest and in transit.
Cardholder data is never received by Seilfi. Payment is taken on Stripe's hosted payment page and card details pass directly from the payer to Stripe.
Order data is reduced to aggregated per-product sales counts before storage; individual orders are not retained.

Segregation and data minimisation

Each Merchant's data is stored under its own store identifier and is never read across stores.
The App requests only the Shopify permissions listed in Schedule 1 and does not request access to customer records.
Shopify privacy request logs record only the request type, store and identifiers.

Availability, resilience and backup

*Vercel operates across multiple fault-independent availability zones and maintains regular, encrypted backups and a business continuity and disaster recovery plan.
*Upstash retains backups of a deleted database for at most four weeks.
*Resend retains backups for seven days.
The App's functions run in the Dublin region and the database is located in AWS eu-west-1 (Dublin).

Logging, monitoring and incident response

Application logs are retained by Vercel for one day and are reviewed when a fault or security event is suspected.
Seilfi maintains a written incident response procedure providing for containment, assessment, notification to Merchants under clause 10 and post-incident review.
*Vercel, Upstash and Resend each maintain incident response programmes and commit to notify Seilfi of personal data breaches without undue delay.

Testing and assurance

*Vercel, Upstash and Resend each hold SOC 2 Type II reports and conduct penetration testing and vulnerability scanning of their platforms.
Seilfi reviews the Security Measures at least annually and following any personal data breach.
Seilfi reviews the security documentation of each Sub-processor at least annually.

Personnel and confidentiality

All Seilfi personnel and contractors with access to Merchant Personal Data are bound by written confidentiality obligations and receive data protection guidance appropriate to their role.

Deletion

Shopify access tokens are deleted immediately on uninstallation. All other data for a store, including staff passcode records, is deleted on receipt of Shopify's shop redact request, as described in clause 12.
Data held under the retention periods in Schedule 1 is deleted automatically when the period expires.

Schedule 3: Approved Sub-processors

Sub-processor	Purpose	Location of processing	Transfer mechanism
Vercel Inc., 440 N Barranca Ave #4133, Covina, CA 91723, United States	Application hosting, serverless functions, scheduled jobs and application logs	App functions run in Vercel's Dublin, Ireland region (dub1). Requests are routed through Vercel's global edge network. Backups are replicated across regions. Runtime logs are retained for one day.	Standard Contractual Clauses (Module Three) incorporated in Vercel's Data Processing Addendum; EU-US Data Privacy Framework certification. Vercel gives at least 10 days' notice of new sub-processors.
Neon Inc., a Delaware corporation, United States	Database (PostgreSQL) storing the records described in Schedule 1, including the Merchant's catalogue, locations, stock ledger, uploaded files and account records	Database in Amazon Web Services region eu-central-1 (Frankfurt, Germany). Neon Inc. may access data from the United States for support and operations.	Standard Contractual Clauses (Module Three) incorporated in Neon's Data Processing Addendum. Notice of new sub-processors by publication at neon.com/trust. The database was provisioned on 14 October 2026 through the Vercel Marketplace; the contract for the database is with Neon directly.
Upstash, Inc., a Delaware corporation, United States	Database (Redis) for the Shopify edition of the App only	Dedicated database in Amazon Web Services region eu-west-1 (Dublin, Ireland). Upstash Inc. may access data from the United States for support and operations.	Standard Contractual Clauses (Module Three) incorporated in Upstash's Data Processing Addendum (April 2025); EU-US Data Privacy Framework certification. Notice of new sub-processors by publication at trust.upstash.com.
Plus Five Five, Inc. (trading as Resend), 2261 Market Street #5039, San Francisco, CA 94114, United States	Sending report and alert emails on the Merchant's behalf	Resend stores message content, recipient addresses and delivery logs in the United States for 30 days, with backups for a further 7 days, whichever sending region is selected.	Standard Contractual Clauses (Module Three) incorporated in Resend's pre-signed Data Processing Addendum; EU-US Data Privacy Framework certification. Resend gives at least 14 days' notice of new sub-processors.

Shopify International Limited and its affiliates are not Sub-processors of Seilfi. Where the Merchant connects a Shopify store, Shopify is the Merchant's own platform provider, and for Merchants who subscribed through the Shopify App Store it is also their billing agent; in both cases it processes the Merchant's store data and subscription payments under the Merchant's own agreements with Shopify. Merchants using the standalone edition of the App have no relationship with Shopify through Seilfi.

Stripe Payments Europe, Limited and its affiliates are not Sub-processors of Seilfi. Seilfi uses Stripe's hosted payment page, so cardholder data passes directly from the payer to Stripe and is never received, stored or processed by Seilfi. Stripe acts as a separate controller of the payment data it collects, under its own terms and privacy policy. Seilfi receives only the subscription's plan and status, the billing period, and the billing name, address and any VAT number required to issue an invoice and apply the correct rate of VAT.

Each Sub-processor's contract with Seilfi incorporates the UK International Data Transfer Addendum and the Swiss modifications to the Standard Contractual Clauses, for the purposes of clauses 8.6 and 8.7.

Each Sub-processor above engages its own sub-processors, whose lists are published by the Sub-processor. Seilfi's contract with each Sub-processor requires the Sub-processor to impose equivalent obligations on those parties and to remain liable for them.

Schedule 4: Suggested privacy wording for the Merchant's staff

"We use an inventory app called Seilfi to count and audit our stock. When you use Seilfi you will be asked to type your name so that the app can record who carried out each count. Your name, and any comments you type in an audit or stock take, are stored in the app and included in the stock reports that are emailed to [names or roles of recipients]. If you are chosen to receive reports, your work email address is stored in the app for that purpose. Seilfi is provided by Hygge Tygge Ventures Limited, an Irish company, which stores the data within the European Economic Area and uses service providers in the United States under approved contractual safeguards. Your name is kept with each count for up to 120 days, or up to 400 days in stock-level snapshots. We use this information to manage our stock accurately, which is in our legitimate business interest. You can ask us to see, correct or delete your information by contacting [name]. You can also complain to the Data Protection Commission."