This Data Processing Addendum (“DPA”) forms part of the Merchant Terms between Arete Technologies LLC (“Pidge”) and the business using Pidge (“Merchant”). It applies when Pidge processes personal data on the Merchant’s behalf.
1. Roles
- For program data (a member’s visits, purchase amounts, balances, rewards, “usual” notes and messages relating to the Merchant’s program), the Merchant is the controller and Pidge is the processor.
- For the member’s Pidge account (sign-in, profile and activity across shops), Pidge is an independent controller under its Privacy Policy.
2. Details of processing
| Subject matter | Running the Merchant’s loyalty program and Carrier messages |
|---|---|
| Duration | The term of the Merchant Terms plus 30 days for export |
| Data subjects | The Merchant’s members; the Merchant’s staff users |
| Personal data | Display name, email (for staff lookup), visit times, purchase amounts, balances, rewards, optional birthday (month and day), staff notes, message delivery and open status; staff email, name, role and audit log |
| Special categories | None intended. Merchants must not enter them in notes. |
3. Pidge’s commitments
- Process program data only on the Merchant’s documented instructions, which are the Merchant Terms, this DPA and the Merchant’s settings in the dashboard.
- Ensure people with access are bound by confidentiality.
- Keep appropriate technical and organizational security measures, including encryption in transit, hashed sign-in codes and API keys, role-based staff access, audit logging of staff actions and rotating member QR codes.
- Notify the Merchant without undue delay, and within 72 hours where feasible, after becoming aware of a personal data breach affecting program data.
- Help the Merchant respond to data subject requests and with data protection impact assessments where reasonably required.
- At the end of the service, delete program data after the 30-day export window unless the law requires keeping it.
- Make information available to demonstrate compliance, and allow reasonable audits no more than once a year with 30 days’ notice.
4. Subprocessors
The Merchant authorizes Pidge to use the subprocessors below. We’ll give at least 30 days’ notice of a new subprocessor by email, and the Merchant may object on reasonable data protection grounds.
| Subprocessor | Purpose | Location |
|---|---|---|
| Convex, Inc. | Database, backend functions and file storage | USA |
| Cloudflare, Inc. | Website hosting, CDN, security and transactional email (sign-in codes, invites) | Global |
| Expo (650 Industries, Inc.) | Push notification delivery | USA |
| Apple Inc. | Push notifications (APNs), Sign in with Apple | Global |
| Stripe, Inc. | Subscription billing for businesses | USA |
| PostHog, Inc. | Product analytics, session recordings and crash reports | USA |
| The Merchant’s POS provider | POS integration, only when the Merchant connects it | Per provider |
5. International transfers
Where program data is transferred from the EEA, UK or Switzerland to a country without an adequacy decision, the parties rely on the European Commission’s Standard Contractual Clauses (Module 2 or 3, as applicable) and the UK Addendum, which are incorporated by reference.
6. Merchant’s commitments
The Merchant is responsible for having a lawful basis for its program and messages, for the accuracy of its instructions, and for telling members how their data is used at its shop.
Contact
Data protection questions: privacy@hellopidge.com.