Legal
Data Processing Addendum
Last updated October 2026
This Data Processing Addendum ("DPA") supplements the Terms of Service when NeonTech Ventures LLC ("Sublyra", "Processor") processes personal data on behalf of a merchant ("Controller") in connection with the Sublyra Shopify app.
Roles
The merchant is the controller (or processor for their customers). Sublyra acts as a processor for app data required to provide the service. Shopify may act as an independent controller or processor under its own terms for checkout and payments.
Subject matter
Processing is limited to operating subscription contracts, selling plans, portal actions, retention features, analytics for the merchant, and related support. Shopper payment card data is not processed by Sublyra.
Instructions
We process personal data only on documented instructions from the merchant (including configuration in the app) and as required to provide the service, unless otherwise required by law.
Security
We apply encryption in transit, access controls, least-privilege credentials, and secure hosting practices. See also /security.
Subprocessors
We may use subprocessors for hosting and email delivery as described in the Privacy Policy. We remain responsible for their performance under this DPA.