the fine print, in plain words
Data processing agreement
Last updated · Octopods Software Systems Limited (Republic of Ireland)
For merchants whose legal team needs it: what we process on your behalf, what we don't, and what we owe you as your processor. Version 1.
1. Parties and roles
The merchant using CommerceReply is the controller of its buyers' personal data. Octopods Software Systems Limited is the processor, and processes that data only on the merchant's documented instructions.
2. Subject matter, duration and purpose
We process data to carry buyer messages between the merchant's TikTok Shop and Intercom workspace, and to provide the other features the merchant uses, for as long as the merchant's subscription lasts.
3. Types of data
- Buyer identifiers, and the link between each TikTok buyer thread and its Intercom conversation
- Buyer messages and replies, including anything a buyer types into them, processed on the fly to deliver them and never stored
- Shop and workspace identifiers, and the tokens that keep each connection alive
- Names and work emails of the merchant's staff who use the service
Not stored
- Message content. Buyer messages and replies are processed on the fly and never written to storage.
- Buyer names, phone numbers or addresses that TikTok masks. We pass the masked values to the screen without writing them down.
4. Data subjects
The merchant's buyers, and the merchant's staff who use CommerceReply.
5. Our obligations
- Process data only on the merchant's instructions, and keep it confidential.
- Apply the security measures described on our security page.
- Help the merchant answer requests from buyers exercising their rights.
- Tell the merchant without undue delay after becoming aware of a personal data breach.
6. Subprocessors
The merchant authorises the subprocessors on our subprocessors page, and we tell merchants before we add one.
7. International transfers
Where data is processed outside the European Economic Area, we rely on a European Commission adequacy decision or the Standard Contractual Clauses.
8. Deletion at the end
When the subscription ends, or a shop or workspace is disconnected, we delete the related data or return it if the merchant asks, unless the law requires us to keep it.
9. Audits
We make available the information needed to show we meet these obligations, and allow for reasonable audits.
10. Get a copy
This page summarises the agreement. To receive the full document, or a copy countersigned for your records, write to team@commercereply.com.
Questions about this page? Write to team@commercereply.com.