Data processing agreement

In force from 8 October 2026

This agreement is part of the terms of service between Avatud Lahendused OÜ (“Tieroo”, “we”, the processor) and the business that uses Tieroo (“you”, the controller). It covers the personal data of your customers that we process to run your loyalty cards, as Article 28 of the GDPR requires. You accept it when you connect your Odoo to Tieroo.

1. What we process and why

  • Purpose: to build your customers' loyalty cards in Apple Wallet and Google Wallet, keep them up to date and send the notifications described in our privacy policy. Nothing else.
  • Data subjects: your customers who hold a Tieroo card, and the contact persons of your business customers when a card is issued to them.
  • Personal data: name, and for a company card the company's name; points, rewards, expiry dates of points and of the card, and with Customer Levels the level; the card's language; card identifiers (the QR code and your Odoo record number); the push tokens and device identifiers of the phones the card is on and when it was added; if you show the card near your shops, which of your shops are on that customer's card.
  • Not processed: email addresses, purchase history and the location of your customers. Your Odoo keeps the customer records and sends the emails.
  • Duration: as long as you use Tieroo, and then until the data is deleted under section 8.

2. Your instructions

We process the data only on your documented instructions. Your instructions are these terms, this agreement and what your Odoo sends us through the Tieroo module and the card designer. If we think an instruction breaks data protection law, we tell you. If the law requires us to process data in another way, we tell you first, unless the law forbids it.

You are responsible for the lawful basis of the processing and for telling your customers about it, including that the card may carry the coordinates of your shops if you switch that on.

3. Our duties

  • Everyone at Tieroo who can access the data is bound to confidentiality.
  • We take the security measures in section 4.
  • We help you answer your customers' requests to exercise their rights. Most need nothing from us: changing or deleting the customer in your Odoo changes or erases the card.
  • We help you with security, breach notifications, data protection impact assessments and consulting the supervisory authority, as far as our part of the processing goes.

4. Security

  • Data travels encrypted (TLS) between your Odoo, our servers, Apple, Google and the phones.
  • Each merchant's data is separated in the database by row-level security: one merchant's key cannot read another's cards.
  • Servers sit in a private network; only the service's public addresses are reachable from the internet. Administration goes through a VPN and SSH keys only.
  • Your sync key is stored only as a hash. Links to a card are signed and expire after 48 hours, or earlier once the card is on a phone.
  • Backups are encrypted and kept in the EU.
  • Security updates are installed automatically.

5. Sub-processors

You allow us to use the sub-processors listed in our privacy policy. We bind each one to data protection terms no weaker than these. We tell you by email at least 30 days before we add or replace one; if you object on reasonable grounds and we cannot meet them, you may end the service before the change takes effect. We remain responsible for our sub-processors.

6. Transfers outside the EU

Apple and Google receive what they need to show and update a card in their wallet and may process it in the USA. Such transfers rely on the safeguards these companies provide under Chapter V of the GDPR, such as the EU Standard Contractual Clauses or the EU-US Data Privacy Framework. Our own servers and backups are in the EU.

7. Personal data breaches

We tell you without undue delay after we become aware of a breach affecting your customers' data, with what we know about its nature, the data and people concerned, its likely consequences and what we are doing about it. We add details as we learn them.

8. Deletion

  • When you delete a customer in Odoo, we erase their data from the card at once.
  • When a card is closed (the loyalty card or the customer archived, or the Tieroo module uninstalled), we erase its data 30 days later, unless your Odoo opens the card again.
  • When you close your Tieroo account, we delete all your data 90 days later, unless you open the account again before then.
  • Erased data leaves the encrypted backups as they are overwritten.

What remains of an erased card is a closed card with only its random code, so the phone shows it greyed out. Your loyalty data stays in your Odoo throughout.

9. Information and audits

We give you the information you need to show that this agreement is kept, and answer your questions about it in writing. If that is not enough, you or an auditor bound to confidentiality may audit our compliance once a year, with 30 days' notice, at your cost.

10. General

This agreement lasts as long as we process your customers' data. Where it conflicts with the terms of service on data protection, this agreement wins. Liability follows the terms of service. Estonian law applies.

Contact: Avatud Lahendused OÜ, Tartu mnt 3, 51013 Tartu, Estonia. support@tieroo.com.