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Data Processing Addendum

DRAFT — not signed counsel. Last updated: July 28, 2026. Request a reviewed copy at mcflyadsmmm@gmail.com before treating this as a contract.

1. Parties & roles

Merchant (Controller) installs Mcfly Analytics. Mcfly (Processor), operated by Marty Smithson, Utah, USA, processes Shopify store data to provide the Total ROAS desk. For waitlist emails sent directly to Mcfly, Mcfly is Controller (see Privacy).

2. Subject matter

Processing of Shopify order totals, opaque customer identifiers, spend aggregates the Merchant enters or syncs, staff session fields from Shopify login, and operational logs — solely to provide Total ROAS, break-even, allocation, and Level-1 cohort LTV features described in the Product and Privacy policy.

3. Nature & purpose

Hosted SaaS processing via Shopify Admin API and webhooks. No path-attribution pixels. No Level 2 customer PII (name, email, phone, address) requested or stored for store customers.

4. Duration

While the app remains installed, then deletion on uninstall / shop/redact per Privacy (subject to short backup / legal hold windows). Temporary ComplianceDataExport packages ≤ 60 days.

5. Types of personal data

6. Categories of data subjects

Merchant staff users; Merchant’s end customers (pseudonymous identifiers and order economics only).

7. Processor obligations (summary)

8. Sub-processors

Current list: Cloudflare, Fly.io, managed Postgres provider, Shopify, Resend (when enabled), FormSubmit.co (waitlist fallback), Google Fonts CDN (marketing site). Full descriptions: Privacy.

9. International transfers

US-based operation and hosting. Transfer mechanisms (SCCs / UK addendum) to be attached by counsel for EU/UK Merchants on request.

10. Liability

Subject to the limitation of liability in the Terms, except where mandatory data-protection law provides otherwise.

11. Contact

mcflyadsmmm@gmail.com · Privacy · Terms