Data processing agreement

Version draft 04-10-2026

Draft — to be reviewed before the paid launch.

1. Roles

You (the seller) are the controller of your buyers' personal data. RefurbDesk is the processor (GDPR art. 28).

2. Purpose

RefurbDesk processes buyer data only to import orders, book sales, create and send invoices and handle returns — on your instructions.

3. Security

• Data separated per company at every level (database, files, cache, background jobs).
• Encryption of marketplace keys and secrets; HTTPS everywhere; optional two-factor login.
• Daily backups; access only for staff who need it.
• RefurbDesk staff can open your account only for support, billing and fixing faults. Staff must use two-factor login, the app shows a banner while they do, and every page they open and every change they make is recorded in an audit log.

4. Sub-processors

Hosting provider (EU), e-mail delivery provider and Stripe (billing). Only when you switch the feature on: Sendcloud (shipping labels — buyer name and address), Phonecheck (device reports by IMEI) and Anthropic (AI reply drafts — the customer-care thread and order facts, not stored by RefurbDesk beyond your inbox). You are informed before a new sub-processor is added.

5. Retention

Buyer addresses can be removed after the period you choose; invoices are kept for the legal retention period (7 years in NL). On cancellation all data is deleted within 90 days, after an export if you ask.

6. Breaches

RefurbDesk informs you without undue delay, and at the latest within 48 hours, of a personal data breach.