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  1. EU Data Protection/

Standard Contractual Clauses (SCCs)

Table of Contents

Last Updated: February 6, 2026

Overview
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These Standard Contractual Clauses (“SCCs”) apply to the transfer of Personal Data from the European Economic Area (EEA), the United Kingdom, or Switzerland to countries outside of these jurisdictions that do not provide an adequate level of data protection as determined by the European Commission.

These SCCs are incorporated into and form part of the Data Processing Agreement (DPA) between Abnoba LLC (“data importer”) and Customer (“data exporter”).

Applicable Standard Contractual Clauses
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Abnoba LLC adopts the Standard Contractual Clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council, as set out in the European Commission Implementing Decision (EU) 2021/914 of 4 June 2021 (“EU SCCs 2021”).

Module Selection
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For the purposes of data transfers under the Services, the following module applies:

Module Two: Controller to Processor

  • Data exporter: Customer (Controller)
  • Data importer: Abnoba LLC (Processor)

Clause-by-Clause Application
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Clause 7: Docking Clause
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The docking clause does not apply to this agreement.

Clause 9: Use of Sub-processors
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(a) General Written Authorization

The data exporter grants general written authorization for the data importer to engage Sub-processors in accordance with Clause 9 and the DPA.

The current list of Sub-processors is maintained on our Sub-processor List page.

(b) Notification and Objection

The data importer shall notify the data exporter at least 30 days in advance of any intended changes concerning the addition or replacement of Sub-processors. The data exporter may object to such changes on reasonable grounds within 14 days of notification.

Clause 11: Redress
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(a) Data Subjects’ Rights

Data subjects may exercise their rights under the SCCs against either the data exporter or the data importer.

(b) Third-party Beneficiary Rights

Data subjects are third-party beneficiaries to these SCCs and may enforce them against the data exporter and/or data importer.

Clause 13: Supervision
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The supervisory authority with responsibility for ensuring compliance by the data exporter with Regulation (EU) 2016/679 shall act as competent supervisory authority for these SCCs.

Clause 17: Governing Law
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These SCCs shall be governed by the law of the EU Member State in which the data exporter is established. In the absence of such establishment, the SCCs shall be governed by the law of Ireland.

Clause 18: Choice of Forum and Jurisdiction
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Any dispute arising from these SCCs shall be resolved by the courts of the EU Member State in which the data exporter is established. In the absence of such establishment, disputes shall be resolved by the courts of Ireland.

Annex I: List of Parties
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A. Data Exporter(s)
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Name: Customer (as identified in the Terms of Service) Address: As provided by Customer during registration Contact person’s name, position and contact details: As provided by Customer Activities relevant to the data transferred: Use of Altera for Shopify store data import/export Role: Controller

B. Data Importer(s)
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Name: Abnoba LLC Address: 7901 4TH St N, Suite 300, St. Petersburg, FL 33702 Contact person: Data Protection Contact Contact details: privacy@getaltera.com Activities relevant to the data transferred: Providing Shopify import/export services via Altera Role: Processor

Annex II: Description of Transfer
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Categories of Data Subjects
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  • Customers of the Shopify store
  • Store administrators and employees
  • Vendors and suppliers (where applicable)

Categories of Personal Data
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  • Names and contact information (email, phone, address)
  • Order and transaction data
  • Product information
  • Inventory data
  • Customer account information
  • Other Shopify store data selected by Customer for processing

Sensitive Data (if applicable)
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Not applicable. Customer must not use the Services to process special categories of data without prior written agreement.

Frequency of Transfer
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Continuous during the term of service, as initiated by Customer.

Nature of Processing
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  • Importing Shopify store data from files or Google Sheets
  • Exporting Shopify store data to files or Google Sheets
  • Temporary storage and transformation of data during operations
  • Validation and error checking

Purpose(s) of Transfer
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To enable Customer to import and export Shopify store data using the Altera services.

Retention Period
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Data is retained only for the duration necessary to complete the requested import/export operation, plus any period required by law or as specified in the Terms of Service. Typically, temporary processing data is deleted within 30 days.

Sub-processors
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As listed on our Sub-processor List page.

Annex III: Technical and Organizational Measures
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Abnoba LLC implements the following technical and organizational measures to ensure the security of Personal Data:

1. Encryption
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  • Data in transit: TLS 1.2 or higher
  • Data at rest: AES-256 encryption

2. Access Control
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  • Role-based access control (RBAC)
  • Multi-factor authentication for system access
  • Regular access reviews and de-provisioning

3. Physical Security
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  • Physical security controls (provided by GCP)
  • Biometric access controls at data centers (provided by GCP)
  • Redundant power and cooling systems (provided by GCP)

4. Operational Security
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  • Regular security patches and updates
  • Automated backup systems (GCP infrastructure)
  • Incident response procedures

5. Application Security
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  • Secure software development lifecycle
  • Code reviews

6. Monitoring and Logging
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  • Audit logs of data access and modifications

7. Business Continuity
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  • Automated backup systems (GCP infrastructure)
  • Redundant infrastructure (GCP)

For more detailed information on our security practices, see our Privacy & Data Handling page.

Annex IV: List of Sub-processors
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See Sub-processor List for the current list of Sub-processors and their processing activities.


Changes to SCCs
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Abnoba may update these SCCs to reflect changes in applicable law or regulatory guidance. Material changes will be communicated to Customers with at least 30 days’ notice.

Contact Information
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For questions about these Standard Contractual Clauses:

Abnoba LLC Email: privacy@getaltera.com