Unagi/Legal

Data processing addendum

Last updated 2 October 2026

This addendum forms part of the terms of service between [Company name] ("Processor") and the customer ("Controller"). It applies where the Processor processes personal data of visitors to the Controller's websites on the Controller's behalf, and reflects Article 28 of the UK GDPR.

1. Details of the processing

Subject matterProviding website analytics to the Controller.
DurationFor as long as the Controller has an account, subject to deletion described below.
Nature and purposeCollecting, storing and analysing behavioural events from the Controller's websites to produce reports and findings for the Controller and, where the Controller enables them, running an automated chat with visitors and sending the emails the visitor asked for.
Types of personal dataPseudonymous visitor and session identifiers; pages, product and search activity; engagement time and scroll depth; coarse device facts (device type, browser, operating system, language, time zone, screen size) and an approximate region; click labels; cart, checkout and purchase events; referrer hostname. Where the Controller enables the chat and email: chat messages, and email address, optional first name and the visitor's consent record. No payment details are intended to be collected. Where the Controller switches them on: approximate or precise location (rounded to about a kilometre), an IP address in the form the Controller chooses (shortened, hashed or full), a telephone number given with separate consent, and a log of each consent given or withdrawn.
Data subjectsVisitors to the Controller's websites.

2. The Processor will

3. The Controller will

4. Sub-processors

The Controller gives general authorisation for the Processor to use sub-processors. The current sub-processors are our infrastructure provider, Namecheap, hosting servers in [server location]; where the Controller enables the chat, Anthropic (generating replies); and where the Controller enables email, Resend (delivering email). The Processor will impose equivalent data protection obligations on sub-processors, remains responsible for their performance, and will tell the Controller before adding or replacing one so the Controller may object.

5. International transfers

The Processor will only transfer personal data outside the UK where an appropriate safeguard permitted by UK data protection law is in place.

6. Contact

Questions about this addendum: uk@youok.uk.