Shopify · Shopify Privacy Policy

Dual Controller/Processor Role

High severity
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What it is

Shopify plays two different roles: it processes your data on behalf of the merchant whose store you visit, but it also collects and uses your data independently for its own purposes like the Shop App and fraud prevention.

Consumer impact (what this means for users)

When you shop at a Shopify-powered store, your personal data may be used by both the merchant (for their own purposes) and Shopify (for platform, advertising, and fraud purposes), meaning you effectively have two data controllers to manage your rights against.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Delete Your Data
    To exercise data rights against Shopify as an independent controller, email privacy@shopify.com with your request. To exercise rights against the merchant, contact that merchant's store directly using the contact details in their own privacy policy.

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Why it matters (compliance & risk perspective)

This dual role creates confusion about who is responsible for protecting your data and who you should contact to exercise your privacy rights, since both the merchant and Shopify have independent obligations and interests.

View original clause language
When you visit a store powered by Shopify, the merchant who operates that store is the data controller of your personal information, and Shopify is the data processor acting on their behalf. However, where Shopify collects personal information for its own purposes — such as to operate the Shop App, improve Shopify's services, or for fraud prevention — Shopify acts as an independent data controller.

Institutional analysis (Compliance & legal intelligence)

REGULATORY FRAMEWORK: This provision directly implicates GDPR Articles 4(7) (controller definition), 4(8) (processor definition), 26 (joint controllers), and 28 (processor obligations including mandatory DPA). The co-controller or independent controller distinction is critical: if Shopify uses storefront customer data for its own purposes, this may constitute joint controllership under Article 26, requiring a formal arrangement between merchant and Shopify. Enforcement authority rests with EU DPAs.

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Applicable agencies

  • FTC
    The FTC has authority over deceptive data practices, including where the identity of the data controller is not clearly disclosed to consumers.
    File a complaint →

Provision details

Document information
Document
Shopify Privacy Policy
Entity
Shopify
Document last updated
April 29, 2026
Tracking information
First tracked
March 15, 2026
Last verified
April 10, 2026
Record ID
CA-P-002680
Document ID
CA-D-00122
Evidence Provenance
Source URL
Wayback Machine
SHA-256
929225abb20671960ed1f40a6325a4c72cf5ea341e79aa8378056b3b66ef5708
Verified
✓ Snapshot stored   ✓ Change verified
How to Cite
ConductAtlas Policy Archive
Entity: Shopify | Document: Shopify Privacy Policy | Record: CA-P-002680
Captured: 2026-03-15 11:22:02 UTC | SHA-256: 929225abb2067196…
URL: https://conductatlas.com/platform/shopify/shopify-privacy-policy/dual-controllerprocessor-role/
Accessed: April 29, 2026
Classification
Severity
High
Categories

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