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.
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.
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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.
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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