This Data Processing Agreement (“DPA”) forms part of the agreement between Hangzhou Yidao Chuhai Digital Technology Co., Ltd., doing business as YEEDOOR (“Processor”), and the merchant that installs Ye Pixel (“Controller” or “Merchant”) for the processing of personal data in connection with Ye Pixel.
For merchants that install or use Ye Pixel, this DPA is incorporated into and forms part of the YEEDOOR Terms of Service.
1. Definitions
- Applicable Data Protection Law means the laws and regulations that apply to the processing of personal data under this DPA, including the GDPR where applicable and applicable United States state privacy laws.
- Controller means the Merchant, which determines the purposes and means of the processing.
- Processor means YEEDOOR, which processes personal data on behalf of the Controller.
- Personal Data means information relating to an identified or identifiable natural person.
- Processing means any operation performed on Personal Data, including collection, storage, use, disclosure, deletion, and destruction.
- Security Incident means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data.
- Services means Ye Pixel and the related analytics, reporting, and conversion measurement features.
- Subprocessor means a third party engaged by the Processor to process Personal Data on behalf of the Controller.
2. Roles and coverage
2.1 The Controller determines why and how Personal Data is processed in connection with the Services. The Processor processes Personal Data only to provide the Services and in accordance with this DPA.
2.2 The Controller is responsible for the lawfulness of its instructions, for providing accurate privacy notices to shoppers, and for obtaining and honoring consent where required.
2.3 The Processor does not sell Personal Data and does not use it for its own advertising or for training models for other merchants.
3. Merchant instructions
3.1 The Processor processes Personal Data only on the Controller's documented instructions, including the settings chosen in Ye Pixel and the destinations the Controller chooses to connect.
3.2 The Processor will promptly inform the Controller if an instruction appears to violate Applicable Data Protection Law, unless the law prohibits doing so.
3.3 The Controller may disconnect a destination or uninstall Ye Pixel at any time. Disconnecting stops future transfers to that destination.
4. Details of processing
The subject matter, duration, nature, and purpose of processing, the categories of Personal Data, and the categories of data subjects are described in Annex A.
5. Confidentiality and personnel
5.1 The Processor limits access to Personal Data to personnel who need it to provide the Services.
5.2 Personnel with access are bound by confidentiality obligations and receive appropriate privacy and security guidance.
5.3 Access is reviewed when roles change and is removed when no longer needed.
6. Security
6.1 The Processor implements and maintains technical and organizational measures designed to protect Personal Data, as described in Annex B.
6.2 The measures include access controls, encrypted connections, protection of stored credentials and matching keys, security records, vendor safeguards, encrypted backups (AES-256-GCM), recovery arrangements, and an incident response process.
6.3 The Processor may update the measures as technology and risks evolve, provided the overall level of protection is not materially reduced.
7. Subprocessors
7.1 The Controller authorizes the Processor to engage the Subprocessors listed in Annex C.
7.2 The Processor will give the Controller reasonable notice of a new Subprocessor and a reasonable opportunity to object. If the Controller objects on reasonable data protection grounds, the parties will discuss a solution in good faith.
7.3 The Processor remains responsible for its Subprocessors' performance of their data protection obligations.
8. International transfers
8.1 Personal Data may be processed in Singapore and in other countries where the Processor or its Subprocessors operate.
8.2 Where required, the parties will rely on appropriate safeguards, including standard contractual clauses or other lawful transfer mechanisms, and will cooperate to complete any additional steps required by Applicable Data Protection Law.
9. Data subject requests
9.1 The Processor will provide reasonable assistance to the Controller in responding to requests from data subjects to access, correct, delete, restrict, object to, or port Personal Data.
9.2 If the Processor receives a request directly, it will refer the request to the Controller unless the law requires otherwise.
9.3 Shopify compliance requests relating to customer access or deletion are handled through the application's established request process. The Processor will delete or irreversibly de-identify the associated records when a valid request is confirmed.
10. Security incidents
10.1 The Processor maintains an incident response process designed to detect, contain, investigate, remediate, and document Security Incidents.
10.2 If the Processor confirms a Security Incident affecting the Controller's Personal Data, it will notify the Controller without undue delay and, where required, no later than 72 hours after confirmation.
10.3 The notification will include, to the extent known:
- the nature of the incident;
- the categories and approximate volume of Personal Data affected;
- the likely consequences;
- the measures taken or proposed to address the incident;
- a contact point for further information.
10.4 The Processor will cooperate with the Controller's reasonable requests and with required regulatory notifications. The Processor will not delay notification to complete a full investigation.
11. Deletion and return
11.1 On termination or upon the Controller's written request, the Processor will delete or return Personal Data in accordance with the retention periods in Annex A, unless retention is required by law.
11.2 Records required for legal, tax, audit, or dispute purposes may be retained for the required period and remain subject to this DPA.
11.3 Backup copies are retained only for the period described in Annex A and are not used for analytics.
12. Audit and documentation
12.1 The Processor will maintain records sufficient to demonstrate compliance with this DPA, including its security measures, Subprocessor list, retention practices, and incident response process.
12.2 The Controller may request a summary of the relevant records and, where required by law or a supervisory authority, conduct an audit on reasonable notice, subject to confidentiality and security requirements.
12.3 Audits will be limited to the systems and information relevant to the Services and will not require the Processor to disclose information about other customers.
13. Liability
13.1 Each party is responsible for its own breach of this DPA.
13.2 Liability limits, indemnities, and insurance are governed by the agreement between the parties, unless Applicable Data Protection Law requires otherwise.
14. Term and termination
14.1 This DPA applies for as long as the Processor processes Personal Data for the Controller.
14.2 Provisions that by their nature should survive termination, including confidentiality, deletion, audit, and liability, will survive.
15. Order of precedence
If this DPA conflicts with the agreement between the parties, this DPA controls with respect to the processing of Personal Data.
16. Contact and signatures
The parties may complete the table below to record their acceptance of this DPA. The Processor's legal name is set out in the right-hand column.
| Controller (Merchant) | Processor (YEEDOOR) |
|---|---|
| Legal name | Legal nameHangzhou Yidao Chuhai Digital Technology Co., Ltd.doing business as YEEDOOR |
| Signature | Signature |
| Name | Name |
| Title | Title |
| Date | Date |
Privacy and data protection contact: aiken@yeedoor.com
Annex A — Details of processing
A.1 Subject matter and purpose
Ye Pixel provides first-party conversion analytics for Shopify merchants. Personal Data is processed to verify orders, attribute conversions, remove duplicate events, prepare merchant reports, and send conversion information to destinations the merchant has connected and authorized.
A.2 Duration
For the term of the merchant's use of Ye Pixel, followed by the retention periods below.
A.3 Categories of data subjects
- Merchant personnel and account contacts.
- Shoppers and visitors of the merchant's store.
A.4 Categories of Personal Data
- Merchant account and support information.
- Storefront activity events, including pseudonymous session and visitor identifiers.
- Verified Shopify order information.
- Shopper name and email address, where the merchant has the required approvals and the shopper has given the applicable consent.
- Limited technical and security information.
A.5 Retention
| Information | Retention |
|---|---|
| Storefront events | Up to 30 days |
| Verified order and attribution records | Up to 24 months |
| Delivery and destination records | Up to 90 days after final status |
| Privacy request records | Up to 24 months |
| Export files | Up to 7 days |
| Security and access records | Up to 12 months |
| Backup copies | Up to 35 days |
A.6 Special categories
The Services are not intended to process special categories of Personal Data. The merchant must not configure Ye Pixel to collect such data.
Annex B — Security measures
The Processor maintains:
- role-based access controls and least-privilege permissions;
- encrypted connections for data in transit;
- protection of stored credentials, matching keys, and customer contact fields through encryption or irreversible hashing;
- security records of administrative and security-relevant activity;
- confidentiality and security commitments with service providers;
- encrypted backups (AES-256-GCM) and recovery arrangements designed to protect availability and data integrity;
- an incident response process with notification commitments;
- periodic review of access, vendors, and security practices.
Annex C — Subprocessors
| Subprocessor | Purpose | Location |
|---|---|---|
| Tencent Cloud | Cloud hosting, storage, and backups | Singapore |
| Google Analytics 4 | Analytics destination connected by the merchant | As configured by the merchant |
| Meta Platforms | Advertising destination connected by the merchant | As configured by the merchant |
| Google Ads | Advertising destination connected by the merchant | As configured by the merchant |
The merchant controls whether a destination is connected. The Processor does not send information to a destination the merchant has not authorized.