Data processing
Data boundary and subprocessors
Launch draft: add the final seller/controller identity, DPA contact, subprocessor notice process, retention language, and transfer safeguards before live sales.
Role summary
For store purchases, licensing, update delivery, and support, the seller acts as the store operator for customer account, license, activation, billing, and support records. Customers remain responsible for the personal data they collect in their own WordPress forms.
Plugin data boundary
Cornerstone Forms Encryption runs on the customer's WordPress site. The license API does not receive form submissions, uploaded files, encrypted values, decrypted values, encryption keys, search keys, audit logs, WordPress user passwords, or customer site cookies.
Store data categories
- Customer email and Stripe customer/subscription identifiers.
- License status, plan, site limit, and activation records.
- Normalized site URL/domain and hashed site identifier for activations.
- Plugin version, WordPress version, and PHP version for license/update checks.
- Support messages and operational diagnostics that customers choose to send.
Subprocessors and service providers
| Provider | Purpose | Data involved |
|---|---|---|
| Stripe | Checkout, subscriptions, tax, receipts, fraud prevention, and Customer Portal. | Billing identity, email, payment metadata, tax/VAT details, subscription ids. |
| Cloudflare | Hosting, Pages Functions, D1, KV, private R2 release storage, security, and email sending where enabled. | Store traffic, license/update API records, release files, operational logs, license email metadata. |
DPA and processor terms
For business customers that require a Data Processing Agreement, the final production page should identify the DPA request channel and the seller's approved process. Do not send form submissions, encrypted values, uploads, passwords, encryption keys, or search keys when requesting a DPA.
Subprocessor changes
The final production policy should explain how customers are notified about new subprocessors or material subprocessor changes, and how they can raise reasonable objections where applicable.
Reference points
- GDPR Article 28 text on processors and subprocessors.
- Stripe Data Processing Agreement.
- Cloudflare Customer Data Processing Addendum.
Review the privacy and security boundaries before launch.
Keep the public privacy notice, support process, DPA contact, and subprocessor list aligned before enabling live checkout.