Data Processing Agreement
This Data Processing Agreement (“DPA”) forms part of, and is governed by, the Terms of Service between you (the “Customer”) and Wardenfox Ltd (company number pending), a company registered in England and Wales whose registered office is to be updated before public launch (“WardenFox”, “we”, “us”). It sets out the terms on which we process personal data on your behalf, as required by Article 28 of the UK GDPR. Where this DPA conflicts with the Terms of Service on data-protection matters, this DPA prevails.
1. Roles of the parties
For personal data about your own customers and contacts that you enter into or generate within the Service, you are the controller and we are your processor. We process that data only to provide the Service and only on your instructions. (Separately, for the personal data of you and your staff as account holders, we are the controller — that is covered by our Privacy Policy, not this DPA.) “Personal data”, “controller”, “processor”, “data subject”, “processing” and “personal data breach” have the meanings given in the UK GDPR.
2. Your instructions
We will process the personal data only on your documented instructions, including on international transfers, unless we are required to do otherwise by law — in which case we will tell you first, unless the law prohibits it. Your use of the Service, together with the Terms of Service and this DPA, are your complete and documented instructions. If we believe an instruction breaches the UK GDPR or other data-protection law, we will tell you.
3. Confidentiality
We ensure that the people we authorise to process the personal data are subject to a duty of confidentiality and process it only as needed to provide the Service.
4. Security
Taking account of the state of the art, the costs of implementation, and the nature, scope, context and purposes of processing, we implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk, in line with Article 32 of the UK GDPR. A summary of those measures is in Annex C.
5. Sub-processors
You give us general authorisation to engage sub-processors to help provide the Service. Our current sub-processors are listed in Annex B. We impose data-protection terms on each sub-processor that are no less protective than those in this DPA, and we remain responsible for their performance. If we add or replace a sub-processor we will give you reasonable notice (for example by updating Annex B and/or our Privacy Policy), and you may object on reasonable data-protection grounds, in which case we will work with you in good faith to find a solution.
6. Assisting you
Taking into account the nature of the processing, we will assist you with appropriate measures, so far as possible, to:
- respond to requests from data subjects exercising their rights (access, rectification, erasure, restriction, portability and objection) — and where a request comes to us directly about your data, we will refer the data subject to you;
- meet your own obligations on security, personal data breaches, and data protection impact assessments and prior consultation (Articles 32–36 of the UK GDPR).
7. Personal data breaches
We will notify you without undue delay after becoming aware of a personal data breach affecting your data, and provide the information you reasonably need to meet your own breach-reporting obligations. You are responsible for notifying the ICO and affected data subjects where the law requires you to.
8. International transfers
Where providing the Service involves a transfer of personal data outside the UK (for example to a sub-processor in Annex B), we will ensure an appropriate safeguard is in place — such as the UK adequacy regulations, the UK International Data Transfer Agreement, or Standard Contractual Clauses with the UK Addendum — and will only transfer what is necessary.
9. Deletion or return
At the end of the Service, you can export your inventory from the Service and request a copy of your other data from us before deletion. If you use the account-deletion flow or ask us to delete the data when the Service ends, we will delete the live personal data from the primary database promptly, unless the law requires us to keep some of it. Residual copies in routine backups are deleted in line with our backup-rotation cycle.
10. Audits and information
We will make available to you the information reasonably necessary to demonstrate our compliance with Article 28, and allow for and contribute to audits, including inspections, conducted by you or an auditor you mandate. To respect the confidentiality and security of our other customers, audits are on reasonable prior notice, no more than once a year (unless required by a regulator or following a breach), at your cost, and we may satisfy an audit request by providing relevant documentation or third-party reports where available.
11. General
This DPA is governed by the laws of England and Wales. If any part of it is invalid or unenforceable, the rest stays in effect. This DPA does not give either party any greater liability than is set out in the Terms of Service.
Annex A — Details of the processing
| Subject matter | Provision of the WardenFox inventory and point-of-sale Service to the Customer. |
|---|---|
| Duration | For as long as the Customer uses the Service and, after deletion, until any residual backup copies expire under our backup-rotation schedule and any legally required retention period ends. |
| Nature & purpose | Hosting, storage, organisation, retrieval, display and processing of the Customer’s records solely to provide and support the Service (including any ecommerce integrations the Customer enables). |
| Types of personal data | Mainly the Customer’s own customers’ and contacts’ names, email addresses, phone numbers, postal/delivery addresses, and order/purchase history; plus any personal data the Customer chooses to enter into notes or custom fields. |
| Categories of data subjects | The Customer’s customers, contacts, and suppliers. |
Annex B — Sub-processors
| Sub-processor | Purpose | Location |
|---|---|---|
| Hosting / infrastructure provider(s) we use from time to time | Application, database, cache and backup hosting | Depends on provider used |
| Cloudflare (if enabled) | DNS, content delivery, bot protection, security & object storage (R2) for uploaded item images | US / global; item images in the EU |
| Email delivery provider (if configured) | Sending service emails | Depends on provider used |
Annex C — Security measures
- Encryption in transit (HTTPS/TLS) and encrypted database connections.
- Strict per-shop data isolation enforced at the database level (row-level security).
- Passwords and till PINs stored only as secure hashes; optional two-factor authentication.
- Role-based access controls and rate limiting against abuse.
- Regular, rotated backups that expire automatically.
- Production deployments are intended to use UK- or EU-located infrastructure, with restricted, loopback-bound internal services.