Data Processing Agreement
The contract that governs how we handle your shoppers' data on your behalf.
Effective 31 October 2026
What this agreement is
This Data Processing Agreement forms part of the Terms of Service and takes effect the moment you create an account. It applies whenever BirunX processes personal data belonging to your shoppers on your behalf.
| Party | Role | What that means |
|---|---|---|
| You (the store owner) | Controller | You decide why your shoppers' data is processed and on what legal basis, and you are their point of contact. |
| BirunX | Processor | We process that data only to provide the service, and only as you instruct. |
Where this agreement and the Terms of Service conflict on a data-protection point, this agreement prevails. On every other point the Terms stand.
Definitions
- Personal data: any information relating to an identified or identifiable person, as defined by the law that applies to you.
- Data protection law: the law that protects your shoppers where they are, including Saudi Arabia's Personal Data Protection Law and Egypt's Law No. 151 of 2020.
- Shopper data: the personal data of your customers that reaches us through your store platform or through our tag.
- Sub-processor: a company we use to help provide the service, which may process shopper data in doing so.
- The service: BirunX, as described in the Terms of Service.
Your instructions
We process shopper data only on your documented instructions. Those instructions are three things and nothing else: the Terms of Service, this agreement, and the settings you choose in your dashboard. Switching a conversion action on is an instruction to send that value; switching it off withdraws that instruction.
We do not process shopper data for our own purposes. We do not sell it, we do not use it to train models, and we do not use one store's data to serve another store.
If we believe an instruction from you would breach data protection law, we tell you and we do not act on it until it is resolved.
Confidentiality
Everyone with access to shopper data is bound to keep it confidential, and that obligation survives the end of this agreement.
Access inside BirunX is limited to the people who need it to operate the service. Your platform and advertising access tokens are encrypted with a key held outside the database, so they cannot be read from a copy of the database.
How we secure the data
These are the measures in place today, not a list of intentions.
| Measure | What it does |
|---|---|
| Encryption in transit | Every connection uses HTTPS. There is no unencrypted path in or out. |
| Encryption at rest | The database is encrypted on disk by the hosting provider. |
| A second layer on your access tokens | Your Google and platform tokens carry AES-256-GCM encryption on top of that, with the key held outside the database. |
| One-way hashing of shopper identifiers | Email, phone, first name, last name and postal code are stored only as SHA-256 fingerprints, which cannot be reversed. |
| No raw payloads | The payload your platform sends is read once and discarded. No column in our database stores it. |
| Row-level security | One store's data is unreachable from another store's session at the database level, not merely hidden by the interface. |
| Rate limiting | Public endpoints are rate limited, tuned so that abuse is resisted without ever dropping a genuine order. |
| No card data | Payment credentials never reach our systems at any point. |
At no point do we hold your shoppers' names, phone numbers, emails or addresses in readable form.
Sub-processors
You give us general authorisation to engage sub-processors. The current list is the "Where your data lives" table in our Privacy Policy, every provider named there is a sub-processor, except the advertising platforms addressed at the end of this section. That table forms part of this agreement, so there is one list and it cannot drift.
Before we add or replace one, we notify you at least 30 days in advance. If you object on reasonable data-protection grounds and we cannot resolve it, you may end your subscription without penalty for the remainder of the paid period.
We stay responsible to you for what a sub-processor does with shopper data, as if we had done it ourselves.
The advertising platforms you connect, Google Ads, Snapchat and TikTok, are not sub-processors. Each receives data because you instructed us to send it, and each acts as an independent controller of what it receives.
Where the data goes
Shopper data is stored in Frankfurt, Germany. The companies that operate the service for us are established in the United States. Providing the service therefore involves transferring data outside your own country.
We rely on the data processing and transfer terms published by each provider, which bind them to protect the data to the standard required of them. We do not move stored data to a new country without giving you the notice described in the previous section.
Helping you answer your shoppers
Your shoppers exercise their rights through you, because you are their controller. Our job is to make that possible.
If a shopper asks to be erased, send us the order reference at support@birunx.com. We clear the fingerprints and click identifiers attached to that order and keep the amounts, so your own reporting stays intact. We answer within 30 days.
Because we hold no readable contact detail for your shoppers, we cannot identify a shopper ourselves. The order reference has to come from you. That is a consequence of collecting less, not a limitation chosen for our convenience.
If there is a breach
If shopper data is exposed, we tell you without undue delay and in any case within 72 hours of becoming aware, with what we know at that point: what happened, which data was involved, roughly how many records, and what we are doing about it.
Notifying the authority about a breach involving your shoppers is your duty as controller: the Saudi Data and Artificial Intelligence Authority in Saudi Arabia, the Personal Data Protection Centre in Egypt. We give you what you need in order to do it, and we notify the authority ourselves where the duty falls on us.
Checking that we do what we say
Once in any twelve months you may ask us in writing for the information you reasonably need to confirm we are meeting this agreement, and we answer within 30 days.
We do not offer on-site audits, and we would rather say so than promise one we cannot host: BirunX has no premises of its own. The service runs on the providers listed in our Privacy Policy, and for the infrastructure layer their own published security documentation and certifications are the evidence.
When you leave
While your account is open you can ask us at any time for a copy of your data in a portable format, and we provide it.
Within 30 days of your account closing we delete shopper data, unless a law requires us to keep something, in which case we keep only that, only for as long as it is required, and it stays subject to the confidentiality clause above.
Changes and notices
If we change this agreement in a way that affects your rights or our duties, we email you before the change takes effect.
Notices under this agreement reach us at support@birunx.com, and reach you at the email address on your account.
Appendix: what we process for you
| Item | Detail |
|---|---|
| Subject matter | Calculating the real profit on each of your orders, and sending that figure to the advertising platform you connect. |
| Duration | For as long as your account exists, plus the deletion window described above. |
| Nature and purpose | Receiving your orders, calculating contribution margin, matching an order to the ad click that produced it, and uploading the result on your instruction. |
| Categories of data subject | Your shoppers: people who placed an order with your store, or visited it while our tag was installed. |
| Categories of personal data | One-way fingerprints of email, phone, first name, last name and postal code; Google click identifiers; an anonymous session identifier; the delivery country; the order's amounts, items and status; and the two Google consent signals. |
| Data we never receive | Names, phone numbers, emails or addresses in readable form; full IP addresses; card numbers or any payment credentials. |
| Sub-processors | As published in our Privacy Policy, incorporated into this agreement by the Sub-processors section above. |