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Shwone LLC Data Processing Agreement

Last Updated: October 24, 2026

This DPA has 2 parts: (1) the Key Terms on this Cover Page and (2) the Common Paper DPA Standard Terms Version 1.1 posted at commonpaper.com/standards/data-processing-agreement/1.1 ("DPA Standard Terms"), which is incorporated by reference. If there is any inconsistency between the parts of the DPA, the Cover Page will control over the DPA Standard Terms. Capitalized words have the meanings given on the Cover Page. However, if the Cover Page omits or does not define a word, the default meaning will be "none" or "not applicable" and the correlating clause, sentence, or section does not apply to this DPA. All other capitalized words have the meanings given in the DPA Standard Terms or the Agreement.

Key Terms

Agreement: This DPA supplements Shwone LLC's Terms of Service, as accepted by Customer.

Approved Subprocessors:

  • Amazon Web Services, Inc. Country of location: United States. Processing: hosting the Service, storing Customer Personal Data (database and files), and sending email.
  • Stripe, Inc. Country of location: United States. Processing: processing payments for Customer's sales.

Provider Security Contact: support@shwone.com

Security Policy: Provider will use commercially reasonable efforts to secure the Service from unauthorized access, alteration, or use and other unlawful tampering.

Service Provider Relationship: To the extent California Consumer Privacy Act, Cal. Civ. Code § 1798.100 et seq ("CCPA") applies, the parties acknowledge and agree that Provider is a service provider and is receiving Personal Data from Customer to provide the Service as agreed in the Agreement and detailed below (see Nature and Purpose of Processing), which constitutes a limited and specified business purpose. Provider will not sell or share any Personal Data provided by Customer under the Agreement. In addition, Provider will not retain, use, or disclose any Personal Data provided by Customer under the Agreement except as necessary for providing the Service for Customer, as stated in the Agreement, or as permitted by Applicable Data Protection Laws. Provider certifies that it understands the restrictions of this paragraph and will comply with all Applicable Data Protection Laws. Provider will notify Customer if it can no longer meet its obligations under the CCPA.

Annex I(A): List of Parties

Data Exporter

  • Name: Customer
  • Address: The address on Customer's account
  • Contact person: The person who holds Customer's account, at the main email address on Customer's account
  • Activities relevant to transfer: See Annex I(B)
  • Role: Controller

Data Importer

  • Name: Shwone LLC (Provider)
  • Address: 5441 S Macadam Ave Ste N, Portland, OR 97239, United States
  • Contact person: Leo Cucinell, CEO, at the address above and support@shwone.com
  • Activities relevant to transfer: See Annex I(B)
  • Role: Processor

Annex I(B): Description of Transfer and Processing Activities

Service: Shwone, the website builder described in the Agreement.

Categories of Data Subjects: Customer's customers: people who buy from Customer, fill in Customer's forms, or sign up for Customer's emails.

Categories of Personal Data:

  • Name
  • Contact information such as email, phone number, or shipping address
  • Transactional information such as orders and what was bought
  • Answers given in Customer's forms
  • Whether a person agreed to receive Customer's marketing emails

Special Category Data: No special category data is Processed.

Frequency of Transfer: Continuous.

Nature and Purpose of Processing: Provider will Process Customer Personal Data as instructed in Section 2.3 of the DPA Standard Terms. The nature of processing includes:

  • Receiving data, including collection, accessing, retrieval, recording, and data entry
  • Holding data, including storage, organization, and structuring
  • Using data, including showing it to Customer and sending the emails Customer chooses to send
  • Updating data, including correcting, adaptation, alteration, alignment, and combination
  • Protecting data, including restricting, encrypting, and security testing
  • Sharing data with Approved Subprocessors, as needed to provide the Service
  • Returning data to Customer
  • Erasing data, including destruction and deletion

Duration of Processing: Provider will process Customer Personal Data as long as required (i) to conduct the Processing activities instructed in Section 2.2(a)-(d) of the Standard Terms; or (ii) by Applicable Laws.

Based on Common Paper's Data Processing Agreement, free to use under CC BY 4.0.