Shopify apps and GDPR data processing: what to check
Every Shopify app that accesses your customers’ data (email, behaviour, purchases) acts as a data processor under GDPR — with precise contractual obligations.
The processor qualification
As soon as an app processes personal data on behalf of the merchant (Klaviyo for emailing, a reviews tool storing customer reviews, an ad pixel transmitting identifiers), its vendor is in principle a processor under Article 28 of GDPR, and the merchant remains the data controller.
What a data processing agreement must cover
Article 28 requires contractual safeguards: subject matter and duration of processing, nature and purpose, security obligations, data fate at contract end, controlled sub-processing. An app's standard terms of service don't always cover these points — you need to verify a specific Data Processing Agreement (DPA) exists.
The often-overlooked point
Many merchants install free or low-cost apps without checking where data is hosted, or whether a DPA exists. An app that transmits data to an unidentified third-party service (an undeclared sub-processor) can constitute a breach, even if the app itself is correctly configured on the cookie side.
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Independent informational content, not affiliated with Shopify. Not legal advice; for an assessment of your situation, consult a lawyer or your DPO.