SETROASFLOW — DPA ANNEX: PROCESSING DETAILS
Version: Draft — 25 August 2026
Controller: Merchant
Processor: SetRoasFlow
Subject matter:
Server-side conversion tracking, customer data infrastructure, CDP, analytics, segmentation, audience activation, personalization, reporting, exports and connected integrations.
Duration:
For the lifetime of the applicable Merchant account/project, subject to earlier deletion by the Merchant and applicable deletion/recovery periods.
Personal data:
- Email; stored in clear in CDP where consent permits; SHA-256 hashed for advertising platforms.
- Phone; SHA-256 hashed for advertising platforms; clear only for configured CRM destinations where permitted.
- External customer ID; SHA-256 hashed.
- Name, surname, city, province/state, postal code and country; hashed before advertising-platform transmission.
- IP address and user-agent; may be sent in clear to supported conversion APIs where permitted.
- Advertising click identifiers.
- Event/context information.
- Country/region and device type.
- Attribution information.
- Derived profile metrics including LTV, AOV, repeat-buyer status, churn risk and predicted LTV.
Special categories:
The Service is not intended for special-category personal data or criminal-offence data. The Merchant must not submit such data.
AI:
The Service is designed not to submit end-customer personal data to AI features. Merchant-provided free text is forwarded as typed and may contain personal data.
Processing operations:
Collection, transmission, normalization, hashing, identity resolution, storage, analytics, segmentation, activation, export and deletion.
Retention/deletion:
Live CDP profiles remain for the account/project lifetime unless deleted earlier. Event records are retained for a rolling period of 24 months. Project deletion removes applicable live data within 24 hours. Residual provider recovery copies may persist for limited periods before automatic expiration.
Operator access:
Authorized SetRoasFlow personnel may have technically possible administrative access to production data stores for operations, debugging and support, subject to organizational and contractual restrictions.