Segmented — Data Processing Agreement
Last updated: October 20, 2026
1. Parties and scope
This agreement governs the processing of personal data by Segmented, operated by Nathaniel Hayoun, entrepreneur individuel (sole proprietorship), SIREN 880 917 604, Strasbourg, France (the “Processor”), on behalf of the merchant using the App (the “Controller”), within the meaning of Article 28 of the GDPR. It applies as soon as the merchant installs the App and for as long as it is installed.
2. Nature and purpose of the processing
Customer segmentation and storefront content personalization. Categories of data: customer identifiers, purchase history (orders, line items, amounts, discount codes, billing country and province), tags and metafields, storefront browsing events, and — read live from Shopify without being stored — name, email, phone and address when the content or the merchant's staff need them. Data subjects: the customers and storefront visitors of the Controller. Details are given in the privacy policy.
3. Instructions
The Processor processes the data only on the Controller's documented instructions — the configuration of the App constitutes these instructions — and only to provide the App's features. The data is never sold or used for any other purpose.
4. Confidentiality and security
The Processor implements appropriate technical and organizational measures: encryption in transit (TLS), encryption of third-party credentials at rest, encrypted daily backups (AES-256), database reachable only from the application server, key-only SSH access, logging of access to personal data, access limited to the App's maintainers, who are bound by confidentiality, and an incident response procedure.
5. Sub-processors
Hetzner Online GmbH (hosting in Helsinki, Finland, and encrypted backups in Nuremberg, Germany — European Union). If the Controller connects Klaviyo (United States), customer emails are sent to Klaviyo to read engagement data, under the Controller's own Klaviyo account and API key. The Processor will inform the Controller of any intended change of sub-processor, giving the Controller the opportunity to object by uninstalling the App.
6. Data subject rights
The Processor assists the Controller through Shopify's privacy webhooks: export of a customer's data (customers/data_request, available in the App's Settings), erasure of a customer (customers/redact) and erasure of all the shop's data (shop/redact).
7. Retention
Purchase data and segment memberships: while the App is installed, deleted at uninstall. Storefront events and engagement metrics: 24 months. Access logs: 12 months. Data request exports: 90 days. All remaining data of the shop is deleted upon the shop/redact webhook. Encrypted backups: daily kept 14 days, weekly 8 weeks, monthly 12 months.
8. Personal data breaches
The Processor notifies the Controller without undue delay, and at the latest 72 hours after becoming aware of a breach, with the information required by Article 33 of the GDPR.
9. Audits
The Processor makes available the information reasonably necessary to demonstrate compliance with this agreement (description of the measures, relevant records).
10. End of processing
When the App is uninstalled, the data is deleted as described in section 7. No copy is kept beyond the encrypted backups, which rotate as described in section 7.