Relay

Data Processing Addendum

Last updated 4 November 2026

A boutique's records include personal data about other people: its shoppers, its staff, the sales reps on its vendor orders. Relay handles that data for the boutique and on its instructions. This addendum sets out how.

This Data Processing Addendum (“DPA”) is part of the Terms of Service between CairnRock Solutions, LLC (“Relay”, “we”) and the business that uses Relay (“the store”, “you”). It applies whenever Relay processes Store Personal Data. If this DPA and the Terms disagree about personal data, this DPA wins.

  1. Words used here
  2. Who does what
  3. Your instructions
  4. Confidentiality
  5. Security
  6. Subprocessors
  7. Helping with requests
  8. Breach notice
  9. Deletion and return
  10. Audits
  11. Data outside the United States
  12. US state privacy law
  13. General
  14. Annex 1: the processing
  15. Annex 2: security measures

1. Words used here

2. Who does what

For Store Personal Data, you are the controller (or “business”) and Relay is your processor (or “service provider”). You decide why the data is processed; Relay processes it for you. You are responsible for having a lawful basis and giving any notices your shoppers, staff and vendors need, including telling them that you use service providers like Relay.

Relay is the controller of its own account, billing, support and website records, as the Privacy Policy describes. This DPA does not cover those.

3. Your instructions

Relay processes Store Personal Data only on your documented instructions. Your instructions are: the Terms and this DPA; the way you set up and use Relay (the systems you connect, the settings you choose, the orders you approve); and anything else you ask in writing that we agree to. Those instructions include Relay learning from your store's records to improve the results it gives your store, and adding your store's de-identified sell-through counts to totals across stores, as section 9 of the Terms describes. Those totals contain no personal data.

We tell you if we think an instruction breaks data protection law, and we do not have to follow it. If the law makes us process Store Personal Data in another way, we tell you first unless the law forbids it.

4. Confidentiality

Everyone at Relay who can reach Store Personal Data is bound to keep it confidential, and reaches it only to provide, support or secure the service.

5. Security

Relay keeps the technical and organisational measures in Annex 2, and reviews them as the service and the risks change. We may change them, as long as the overall level of protection does not go down.

6. Subprocessors

7. Helping with requests

If a shopper, a member of staff or anyone else asks Relay directly to see, correct or delete Store Personal Data, we tell you and do not answer them ourselves, except to say they should contact you. Relay helps you answer such requests: owners can see, correct and delete records in Relay, export much of it from the pages that show it, and ask us at privacy@relay.boutique for anything they cannot do themselves. We also give reasonable help with data protection impact assessments and with questions from a regulator about Relay.

8. Breach notice

If Relay becomes aware of a Breach, we tell the store's owners without undue delay, and in any case within 72 hours of confirming it. We say what happened, what data and how many people it may affect, what we are doing about it, and who to contact. We add details as we learn them, and we help you meet any duty you have to tell regulators or the people affected. Telling you is not an admission of fault.

9. Deletion and return

While your store is open you can export records from the pages that show them, or ask us for a copy. When a store closes, everyone loses access at once and Relay deletes its Store Personal Data 30 days later. You can ask us to delete it sooner. Copies in backups are overwritten in the normal backup cycle and are kept secure until then. We may keep data longer only where the law requires it, and then only for that purpose.

10. Audits

Relay shows that it meets this DPA by documentation: once a year, and after a Breach, we answer a reasonable written security questionnaire and give you the information you need to check our compliance. If a regulator requires more, or the documents do not answer a specific, reasonable concern, we agree the scope, timing and cost of any further review with you in advance. Anything you learn this way is our confidential information.

11. Data outside the United States

Relay is a US company. Store records are hosted in the European Union, and some subprocessors are in the United States and elsewhere, as the subprocessor list shows. Where data protection law requires a transfer mechanism for personal data leaving the EU, the UK or Switzerland, the European Commission's Standard Contractual Clauses (and the UK Addendum to them) apply between you and Relay, with Relay as the data importer, and are incorporated into this DPA by reference.

12. US state privacy law

Where the CCPA or a similar US state law applies, Relay is your service provider (or processor) and:

Relay certifies that it understands these restrictions and will comply with them.

13. General

This DPA lasts as long as Relay processes Store Personal Data for you. Each side's liability under it is subject to the limits in the Terms. It is governed by the same law as the Terms, except where data protection law or the Standard Contractual Clauses say otherwise.

Annex 1: the processing

Subject and lengthProviding Relay to the store, for as long as the store uses it, and then until the data is deleted under section 9.
What Relay doesCollecting from the systems the store connects, storing, organising, reading documents with AI models, matching, analysing, displaying, sending to the store's POS or web store when the store says so, and deleting.
People concernedThe store's shoppers; its owners, staff and accountants; its vendors' sales reps and other contacts; anyone pictured in photos the store adds.
Kinds of dataShoppers, as held in the store's POS: name, email, phone, birthday (day and month), whether they accept marketing email, loyalty points, when they joined, their spending and number of purchases each year, and which sales were theirs. Staff: name, email, role, what they did in Relay. Vendor contacts: name, email, phone and other details printed on orders and emails. Photos: a person's likeness, where the store adds one.
Sensitive dataNone intended. The store should not put sensitive personal data (health, financial account numbers, government ID numbers) into Relay.

Annex 2: security measures