Data Processing Addendum (DPA)

The merchant determines visitor-data purposes, use and retention as the primary data user. WoowMind processes questions, necessary passages, conversations, follow-up intent and contact details only on instructions recorded in the terms and product settings, to provide retrieval, reranking, answers, Widgets, storage, export, deletion, security and support.

The merchant must have lawful, fair collection purposes and authority to submit data, give visitors accurate collection and privacy notices including Hong Kong and Beijing processing, minimise collection, handle rights requests, and avoid unconsented marketing, resale or incompatible use. Agreeing to this addendum does not replace the merchant’s duties to notify visitors and obtain any legally required consent.

WoowMind applies reasonable access controls, transport encryption, tenant isolation, minimisation and expiry cleanup; limits access to necessary personnel and providers; and does not use merchant content for model training. Automated de-identification does not guarantee anonymisation. After confirming a security incident affecting merchant data, we notify and assist the merchant as soon as reasonably practicable.

The merchant authorises the providers listed in the Service Provider List. Application, database, storage and retrieval indexes are in Hong Kong. Rewriting, embeddings and answers use a Hong Kong workspace with Hong Kong inference scope. Hosted reranking sends queries and necessary candidate passages to Beijing in mainland China. Complete lead records, local mappings and payment-card data are not added as reranking inputs; questions and passages may still contain personal data.

Google sign-in and Paddle billing serve WoowMind platform accounts and transactions; they are not general processors of merchants’ Widget visitor data. Each party has responsibilities for its own purposes under its applicable terms.

WoowMind assesses provider purpose limits, confidentiality, security, retention, deletion, onward processing and incident arrangements against the applicable agreement and available written confirmations, and helps relay relevant rights requests. China-site Model Studio invocation and security records follow its agreement and legal requirements. This addendum does not promise Beijing Zero Data Retention, a uniform fixed maximum period or immediate per-record deletion upstream; local deletion is not synchronous upstream deletion.

Before material provider, location or purpose changes, we update the documents and give appropriate notice; any legally required additional consent is obtained first. Merchants with location restrictions or reasonable objections should contact privacy@woowmind.com. Until a suitable alternative is arranged, stop submitting affected data; existing export, deletion and Widget-disable functions remain available.

Merchants can export Widget leads and conversations or delete individual records. Each lead and conversation expires 30–365 days after first storage under the merchant’s setting; incomplete lead state expires after 48 hours. Termination and account deletion follow the published local deletion and protected-backup arrangements, subject to legally required retention. Provider-side records follow section 5.

Necessary data may be retained under restricted access, without ordinary service use, for an open data-rights request, documented dispute or legal requirement. We review the continuing need. When it ends, the original expiry rule applies; already expired data is removed in the next normal cleanup, without restarting the retention period.