Subprocessors

It also provides information about:

• What a subprocessor is
• Why WardrobeIt uses subprocessors
• The types of personal data they may process
• The services they provide
• Where processing may take place
• The safeguards applied to their processing
• How WardrobeIt communicates subprocessor changes
• How eligible Merchants may raise a data-protection objection

This notice should be read together with the WardrobeIt Privacy Policy, Data Processing Addendum, Virtual Try-On and Image Privacy Policy, and applicable Merchant agreement.

What Is a Subprocessor?

A subprocessor is a third party that WardrobeIt engages to process personal data on behalf of WardrobeIt when WardrobeIt is acting as a processor for a Merchant.

For example, WardrobeIt may use a subprocessor to provide:

• Cloud infrastructure
• Data hosting
• Database services
• AI processing
• Virtual Try-On image processing
• Security monitoring
• Error logging
• Transactional communications
• Customer support infrastructure
• Service analytics
• Data backup and recovery

A service provider is not automatically a subprocessor merely because WardrobeIt has a commercial relationship with it.

A provider is generally treated as a subprocessor when it processes Merchant Personal Data on WardrobeIt’s behalf to help WardrobeIt deliver the contracted Services.

Scope of This Notice

This notice applies where WardrobeIt processes personal data on behalf of a Merchant under the WardrobeIt Data Processing Addendum or another applicable data-processing agreement.

In that relationship:

• The Merchant generally determines why and how personal data is processed through its storefront and WardrobeIt implementation.
• WardrobeIt processes applicable Merchant Personal Data according to the Merchant’s documented instructions.
• A listed subprocessor may process limited personal data to provide a defined service to WardrobeIt.

WardrobeIt may also process certain information as an independent controller for limited purposes such as account administration, billing administration, security, fraud prevention, legal compliance, and corporate operations. Service providers supporting those activities may not fall within the subprocessor relationship covered by this page.

The exact legal roles may depend on the Service, data, integration, jurisdiction, and applicable agreement.

Why WardrobeIt Uses Subprocessors

WardrobeIt uses carefully selected providers where external infrastructure or specialist services are reasonably necessary to operate the platform.

Subprocessors may help WardrobeIt:

• Host the Merchant Portal and shopper-facing services
• Store and retrieve Merchant Data
• Process shopper requests
• Generate supported AI responses
• Generate eligible Virtual Try-On previews
• Synchronize commerce information
• Deliver transactional emails
• Monitor system availability
• Detect security threats
• Investigate technical errors
• Maintain backups
• Provide support
• Operate subscription and account systems
• Meet legal, privacy, and security obligations

WardrobeIt does not authorize a subprocessor to use Merchant Personal Data for unrelated advertising, independent profiling, data brokerage, or its own unrelated commercial purposes.

Current Subprocessors

The table below should list the subprocessors approved to process Merchant Personal Data in connection with the WardrobeIt Services.

The precise data processed by a provider depends on the WardrobeIt feature, Merchant configuration, shopper activity, and applicable Service.

WardrobeIt will publish only providers that have been approved for production use.

A provider should not be added to this table until WardrobeIt has confirmed:

• Its correct legal entity
• Its actual processing role
• The Service it supports
• The personal data it may receive
• Its processing locations
• Its contractual protections
• Its international-transfer mechanism
• Its retention and deletion commitments
• Whether it may use further subprocessors

Categories of Personal Data

Depending on the Service being supported, a subprocessor may process limited information from the following categories.

Merchant Account and Contact Data

This may include:

• Name
• Business email
• Business name
• Account identifier
• Workspace identifier
• User role
• Authentication and account-status information
• Support contact information

Merchant Store and Configuration Data

This may include:

• Store name
• Store domain
• Integration configuration
• Merchant settings
• Assistant configuration
• Feature settings
• Merchant Knowledge
• Store policies
• Approved brand information

Catalog and Product Data

This may include:

• Product titles
• Product descriptions
• Product images
• Collections
• Product options
• Variants
• Prices
• Product attributes
• Tags
• Synchronized availability
• Product URLs and identifiers

Catalog information may not always be personal data, but it may be processed alongside account or interaction information.

Shopper Interaction Data

This may include:

• Shopper questions
• Conversation content
• Product interests
• Product selections
• Product comparison activity
• Complete-the-Look activity
• Cart-related events
• Session identifiers
• Consent status
• Supported outcome events

Virtual Try-On Information

Where the Merchant enables an eligible Virtual Try-On experience, this may include:

• Submitted shopper image
• Generated preview
• Selected product
• Selected colour or variant
• Consent record
• Processing status
• Error information
• Deletion request information

Virtual Try-On information is subject to the additional protections explained in the Virtual Try-On and Image Privacy Policy.

Technical and Usage Data

This may include:

• IP address
• Browser
• Operating system
• Device type
• Session identifier
• Date and time
• Application events
• Security events
• Diagnostic information
• Error logs
• Integration status
• Service-performance data

Support Data

This may include:

• Support messages
• Store information
• Screenshots
• Technical records
• Error details
• Troubleshooting steps
• Communication history

Merchants must not include passwords, complete access tokens, payment-card information, or unnecessary personal data in support requests.

Categories of Data Subjects

Subprocessors may process information relating to:

• Merchant representatives
• Merchant administrators
• Authorized Users
• Billing contacts
• Support contacts
• Adult shoppers
• Website visitors
• Individuals whose information is included in a Merchant support request

WardrobeIt does not intentionally authorize subprocessors to process children’s images through Virtual Try-On.

Merchants must not enable or promote Virtual Try-On for children without WardrobeIt’s prior written approval and an appropriate legal and safety framework.

Data Minimization

WardrobeIt aims to provide subprocessors with only the information reasonably necessary for the service they perform.

A subprocessor should not receive access to all WardrobeIt data merely because it supports one part of the platform.

Where reasonably possible, WardrobeIt uses measures such as:

• Limiting data fields
• Restricting access by role
• Separating production and test environments
• Masking credentials
• Using temporary identifiers
• Limiting retention
• Restricting image access
• Avoiding unnecessary customer information
• Using aggregated or de-identified information where appropriate

Contractual Requirements for Subprocessors

Before authorizing a subprocessor to process Merchant Personal Data, WardrobeIt requires appropriate contractual protections.

Depending on the provider and processing activity, those protections may require the subprocessor to:

• Process personal data only on documented instructions
• Maintain confidentiality
• Apply appropriate security measures
• Limit access to authorized personnel
• Assist with security incidents
• Support applicable privacy requests
• Delete or return data when required
• Restrict further subprocessing
• Provide relevant compliance information
• Support audits or assurance reviews
• Follow applicable international-transfer requirements
• Notify WardrobeIt of material security or compliance issues
• Avoid unauthorized advertising or independent commercial use
• Avoid unauthorized AI model training

WardrobeIt requires subprocessors to provide data-protection obligations appropriate to the nature and risk of the processing.

Subprocessor Due Diligence

WardrobeIt evaluates relevant subprocessors before production use.

The review may consider:

• The provider’s technical capabilities
• Security practices
• Privacy documentation
• Data-processing terms
• Processing locations
• Data-retention practices
• Incident-response procedures
• Access controls
• Encryption practices
• Available certifications or independent assessments
• International-transfer mechanisms
• Use of further subprocessors
• Ability to delete or return data
• Restrictions on AI training and independent use
• Risks associated with the proposed processing

The scope of review may vary according to the sensitivity, volume, duration, and purpose of the processing.

Listing a provider does not mean WardrobeIt guarantees that the provider will never experience an error, outage, security incident, or legal change.

Security and Confidentiality

WardrobeIt requires subprocessors to apply security measures appropriate to the processing they perform.

Depending on the Service, safeguards may include:

• Encryption in transit
• Encryption at rest where appropriate
• Access controls
• Multi-factor authentication
• Role-based permissions
• Logging and monitoring
• Secure software-development practices
• Vulnerability management
• Backup and recovery controls
• Incident-response procedures
• Employee confidentiality obligations
• Access reviews
• Data-retention controls
• Secure deletion procedures

Access to Merchant Personal Data must be limited to personnel and systems that require it to provide the contracted service.

No security measure can eliminate every risk. WardrobeIt therefore also evaluates incident response, business continuity, and provider cooperation.

International Data Transfers

A subprocessor may process personal data in a country other than the country where the Merchant or shopper is located.

Where an international transfer requires additional protection, WardrobeIt may rely on an applicable mechanism such as:

• An adequacy decision
• European Commission Standard Contractual Clauses
• The United Kingdom International Data Transfer Agreement
• The United Kingdom Addendum to the European Commission Standard Contractual Clauses
• Another legally recognized transfer mechanism
• A permitted legal exception where appropriate

WardrobeIt may also carry out or rely on appropriate transfer-risk assessments and supplementary protections where required.

The applicable transfer mechanism may be identified in:

• The Current Subprocessors table
• The WardrobeIt Data Processing Addendum
• The provider agreement
• A Merchant-specific agreement
• WardrobeIt’s privacy or security documentation

Authorization to Use Subprocessors

Where the WardrobeIt Data Processing Addendum applies, the Merchant authorizes WardrobeIt to use the subprocessors listed on this page, subject to the terms of the applicable agreement.

This authorization may be general or specific depending on:

• The applicable Data Processing Addendum
• The Merchant agreement
• The jurisdiction
• The nature of the processing
• Any separately negotiated requirements

WardrobeIt remains responsible for fulfilling its contractual obligations to the Merchant when a subprocessor processes Merchant Personal Data on WardrobeIt’s behalf, subject to the limitations in the applicable agreement.

Notifications About New or Replacement Subprocessors

WardrobeIt may add, replace, or remove subprocessors as its Services, infrastructure, security needs, and legal obligations develop.

When WardrobeIt makes a material change to the subprocessor list, it may provide notice by:

• Updating this page
• Revising the Last Updated date
• Sending a notice to the Merchant’s registered business email
• Providing a Merchant Portal notification
• Using another method required by the applicable agreement

Where an applicable Data Processing Addendum requires advance notice, WardrobeIt will provide notice according to that agreement.

Merchants are responsible for maintaining accurate account contact information.

To request email notice of material subprocessor changes, contact:

hi@wardrobeit.com

Objecting to a New Subprocessor

Where the applicable Data Processing Addendum gives a Merchant the right to object to a new subprocessor, the Merchant must submit its objection within the period stated in the applicable notice or agreement.

The objection must:

• Be submitted in writing
• Identify the new subprocessor
• Explain the specific data-protection concern
• Be based on reasonable grounds relating to the protection of Merchant Personal Data
• Include information that may help WardrobeIt evaluate the concern

Objections should be sent to:

hi@wardrobeit.com

A general commercial objection, preference for another provider, or objection unrelated to data protection may not qualify as a valid subprocessor objection.

After receiving a valid objection, WardrobeIt may work with the Merchant to consider reasonable options, such as:

• Providing additional information
• Applying further safeguards
• Limiting the affected processing
• Using an available alternative
• Disabling the affected feature
• Agreeing another appropriate resolution

Where WardrobeIt cannot reasonably resolve the objection, the parties may exercise the rights provided in the applicable Data Processing Addendum or Merchant agreement.

This process does not require WardrobeIt to redesign the entire Service or appoint a commercially unreasonable provider.

Emergency Subprocessor Changes

WardrobeIt may need to replace or engage a provider without ordinary advance notice where reasonably necessary to:

• Respond to a serious security issue
• Prevent Service disruption
• Address provider insolvency
• Comply with law
• Respond to a material provider breach
• Protect Merchant or shopper data
• Maintain critical infrastructure
• Address an urgent technical risk

In such circumstances, WardrobeIt will provide notice as soon as reasonably practicable and will apply the required contractual and security review.

Further Subprocessors

A WardrobeIt subprocessor may use its own service providers to support the contracted service.

WardrobeIt requires relevant subprocessors to control further processing through appropriate contractual terms.

Depending on the provider, further subprocessors may support:

• Data-center infrastructure
• Networking
• Content delivery
• Security
• Backup
• Support
• Service monitoring
• AI infrastructure

Where appropriate, WardrobeIt may review a provider’s published subprocessor list, contractual notification process, and objection rights.

WardrobeIt does not necessarily list every lower-level infrastructure provider separately where the primary provider remains contractually responsible for that processing and applicable law does not require separate listing.

Merchant-Selected Integrations

A Merchant may choose to connect WardrobeIt with third-party platforms, such as:

• Ecommerce platforms
• Analytics tools
• Customer-support platforms
• Email and lifecycle systems
• Customer relationship management systems
• Tag-management systems
• Custom storefront technology

A provider selected and controlled directly by the Merchant may be:

• The Merchant’s own processor
• An independent controller
• A joint controller
• Another third party outside WardrobeIt’s subprocessor relationship

Such providers are not automatically WardrobeIt subprocessors.

The Merchant is responsible for:

• Reviewing the provider
• Maintaining the relevant account
• Configuring permissions
• Providing required privacy notices
• Establishing an appropriate legal basis
• Managing the provider’s terms
• Disabling the connection when no longer required

WardrobeIt is not responsible for a third party’s independent processing, security, availability, or legal compliance.

Payment Providers

A payment or subscription provider may process billing information under its own legal terms and privacy obligations.

Depending on the processing activity and applicable law, a payment provider may act as:

• An independent controller
• A separate business
• A service provider
• A subprocessor for limited billing operations

WardrobeIt will identify the provider’s role accurately rather than treating every payment provider as a subprocessor.

WardrobeIt should not receive or store complete payment-card details when the payment provider handles those details directly.

Ecommerce Platforms

A Merchant’s ecommerce platform generally operates under its own terms and privacy policy.

The platform may independently process information relating to:

• Store administration
• Products
• Customers
• Carts
• Orders
• Payments
• Shipping
• Fraud prevention
• Platform security

Connecting WardrobeIt with an ecommerce platform does not automatically make that platform a WardrobeIt subprocessor.

The roles depend on the data flow, contractual relationship, and purpose of processing.

Affiliates

A WardrobeIt affiliate may be treated as a subprocessor where it processes Merchant Personal Data on WardrobeIt’s behalf to provide the Services.

Where applicable, the affiliate should be included in the Current Subprocessors table and subject to appropriate data-protection obligations.

An affiliate that does not process Merchant Personal Data for the Services does not need to be listed solely because it is part of the same corporate group.

Retention and Deletion

Subprocessors may retain personal data only for the period necessary to provide their contracted service, comply with applicable law, protect security, or meet another permitted contractual purpose.

WardrobeIt requires applicable subprocessors to delete or return Merchant Personal Data according to:

• WardrobeIt’s documented instructions
• The provider agreement
• The Data Processing Addendum
• The Merchant agreement
• Applicable retention schedules
• Valid legal requirements

Residual data may remain temporarily in protected backups until overwritten or deleted through the normal backup lifecycle.

A subprocessor must not continue using deleted or expired data for ordinary commercial purposes.

Virtual Try-On images and generated previews are subject to the additional retention commitments described in the Virtual Try-On and Image Privacy Policy.

Security Incidents

WardrobeIt requires relevant subprocessors to notify WardrobeIt of confirmed security incidents affecting Merchant Personal Data without undue delay and according to their contractual obligations.

WardrobeIt may require a subprocessor to provide information concerning:

• The nature of the incident
• The affected systems
• The data involved
• The likely consequences
• Containment measures
• Remediation steps
• Ongoing risks
• Available investigation results

WardrobeIt will manage Merchant notification according to the applicable Data Processing Addendum, Merchant agreement, and legal requirements.

A subprocessor should not notify a Merchant or shopper directly unless WardrobeIt authorizes the communication or applicable law requires it.

Privacy Rights and Assistance

Where required by the applicable agreement, WardrobeIt requires subprocessors to assist with requests involving:

• Access
• Correction
• Deletion
• Restriction
• Objection
• Portability
• Consent withdrawal
• Information about processing

The Merchant generally remains responsible for responding to shopper requests where the Merchant controls the relevant processing.

WardrobeIt may coordinate with its subprocessors where their assistance is needed to locate, restrict, export, or delete applicable information.

Audits and Compliance Information

WardrobeIt may evaluate a subprocessor using appropriate forms of assurance, including:

• Security questionnaires
• Privacy reviews
• Contractual assessments
• Independent audit reports
• Compliance certifications
• Penetration-test summaries
• Security documentation
• Data-flow reviews
• Transfer assessments
• Incident history
• Provider meetings

The exact information available may be subject to confidentiality, security restrictions, and the provider’s contractual terms.

WardrobeIt may provide relevant compliance information to eligible Merchants according to the applicable Data Processing Addendum.

WardrobeIt is not required to disclose information that would compromise security, violate another party’s rights, or expose another customer’s confidential data.

No Sale of Merchant Personal Data

WardrobeIt does not authorize subprocessors to sell Merchant Personal Data or Virtual Try-On images.

Subprocessors may process personal data only for the contracted purpose, WardrobeIt’s documented instructions, and any processing legally required of the provider.

Where a provider acts independently for a separate purpose, that independent activity must be evaluated and disclosed according to the provider’s actual legal role.

AI Model Training Restrictions

A provider supporting AI or Virtual Try-On functionality must not use Merchant Personal Data, shopper conversations, submitted images, or generated previews to train a general-purpose AI model for its own independent purposes unless:

• WardrobeIt has expressly approved the use
• The Merchant has authorized the use where required
• The affected individual has received an appropriate notice
• Separate consent has been obtained where required
• Applicable law permits the processing
• The relevant contract allows the processing

Consent to use WardrobeIt or generate a Virtual Try-On preview is not automatically consent for general-purpose AI model training.

Relationship with the Data Processing Addendum

This page provides transparency about WardrobeIt’s subprocessors. It does not replace the WardrobeIt Data Processing Addendum.

Where the Data Processing Addendum applies, it governs matters such as:

• Processor obligations
• Merchant instructions
• Confidentiality
• Security
• Subprocessor authorization
• International transfers
• Privacy-rights assistance
• Security incidents
• Deletion
• Audits
• Liability
• Termination

Where this page conflicts with an executed Data Processing Addendum, the executed Data Processing Addendum controls to the extent of the conflict.

Changes to This Notice

WardrobeIt may update this Subprocessor Notice to reflect:

• A new provider
• A provider replacement
• A provider removal
• A legal-entity change
• A change in processing purpose
• A change in data categories
• A new processing location
• A transfer-mechanism change
• A material Service change
• A legal or regulatory requirement

The revised page will display an updated Last Updated date.

Material changes may also be communicated according to the Merchant’s agreement or notification preferences.

Contact WardrobeIt

Questions about WardrobeIt subprocessors, international transfers, data-processing terms, or subprocessor notifications may be sent to:

hi@wardrobeit.com