Data processing agreement — Churned

This agreement applies between Churned B.V. (“Churned”, the processor) and the merchant who installs the Churned app (the controller), and forms part of the terms of service. It is accepted when the app is installed. It is written to satisfy Article 28 of the GDPR.

1. What is processed, and why

Churned processes personal data only to provide the service the merchant installed the app for: keeping a current copy of the store's customers, orders and fulfilments, and reporting on retention from it. Categories of data: name, email address, telephone number, postal address, marketing-consent status, order history and the totals derived from it. Data subjects: the merchant's customers. Duration: for as long as the merchant uses the app, and no longer than section 6 allows afterwards.

2. Instructions

Churned processes personal data only on the merchant's documented instructions, which are given by installing the app, by the settings the merchant chooses in it, and by any written instruction sent to support@churned.io. Churned does not sell personal data, does not use it for advertising, and does not use one merchant's data to serve another. Churned makes no automated decision producing legal or similarly significant effects on a customer.

3. Confidentiality and staff access

Access to customer data is limited to named staff who need it for support, through an operator console scoped to one merchant at a time and through scoped API tokens. There are no shared accounts. Access is reviewed quarterly and removed on the day someone leaves. Staff are bound to confidentiality.

4. Security measures

Access tokens and payment-provider secrets are encrypted at the application layer with a key held outside the database. The production database and its backups run on encrypted volumes. Backups are taken daily by the managed database service, retained thirty days, and restore-tested monthly. Every read of a customer record in the operator console writes an audit entry, every change writes its own entry, and exports and erasures are logged; logs are retained ninety days. Staff accounts on every system that can reach production require a password manager, a minimum of twelve characters and multi-factor authentication.

5. Sub-processors

Hosting and database within the European Union. No other party receives personal data unless the merchant connects one themselves from within Churned. Churned will inform the merchant before adding or replacing a sub-processor that processes personal data, and the merchant may object on reasonable data-protection grounds. Each sub-processor is bound by obligations no less protective than those in this agreement.

6. Erasure and return

When the app is uninstalled, the store's access token is discarded immediately. On a shop redaction request from Shopify the store's mirrored data is erased within 48 hours; on a customer redaction request that customer is erased within 48 hours. Both arrive through Shopify's mandatory compliance webhooks and are handled automatically. A merchant may also request export or erasure directly. Invoices and other records Churned must keep by law are retained for the statutory period and for no other purpose.

7. Assisting the merchant

Churned assists the merchant in answering data-subject requests, in carrying out data-protection impact assessments, and in consultations with a supervisory authority, taking into account the nature of the processing and the information available to Churned. Requests that reach Churned directly from a customer are referred to the merchant rather than answered.

8. Personal data breaches

Churned notifies the merchant without undue delay and in any case within 24 hours of becoming aware of a personal data breach affecting their data, including what is known about the cause, the categories and volume of data involved, and the measures taken. Churned contains within four hours by rotating the affected secret and revoking tokens, notifies the supervisory authority within 72 hours where the GDPR requires it, notifies Shopify where Shopify data is involved, and provides a written post-mortem within one week.

9. International transfers

Personal data is stored and processed within the European Union. Churned will not transfer personal data outside the European Economic Area without a valid transfer mechanism and prior notice to the merchant.

10. Audit

Churned makes available the information needed to demonstrate compliance with this agreement and allows for and contributes to audits by the merchant or an auditor they mandate, on reasonable notice, no more than once a year unless a supervisory authority or a breach requires otherwise.

Churned B.V., Netherlands. Questions: support@churned.io. Last updated 2026-09-18.