Data Processing Addendum

This page summarizes the intended commercial DPA position for merchants using EUWithdrawalButton.app. A signed DPA can be requested by contacting lcg0608@126.com.

For customer withdrawal request data submitted through a merchant's hosted page, the merchant is expected to act as controller and EUWithdrawalButton.app as processor for the hosted workflow.

Processing activities include hosting forms, receiving submissions, generating request numbers, sending transactional emails, storing request logs, and making exports available to authorized merchant users.

EUWithdrawalButton.app uses subprocessors only as needed for hosting, email delivery, billing, security, and operational support. Subprocessor categories are listed on the subprocessors page.

Merchants remain responsible for instructions, lawful basis, retention requirements, customer notices, and response obligations.