Data Processing Addendum

Last updated: Sep 28, 2026

Data Processing Addendum

This Data Processing Addendum (“DPA”) supplements the Enterprise Terms (the “Agreement”) entered into by and between Customer and Nebulock, Inc. (“Company”) (together with Customer the “Parties”). This DPA incorporates the terms of the Agreement, and any capitalized terms that are used but not defined in this DPA shall have the meanings set forth in the Agreement.

Definitions
1. “Authorized Subprocessor” means a third-party entity engaged by Company to process Personal Data in order to provide the Services and that is authorized in accordance with Section 6.
2. “Company Account Data” means personal data that relates to Company’s relationship with Customer, including the names or contact information of individuals authorized by Customer to access Customer’s account and billing information of individuals that Customer has associated with its account.
3. “Company Usage Data” means Service usage data collected and processed by Company in connection with the provision of the Services, including without limitation data used to identify the source and destination of a communication, activity logs, and similar data.
4. “Data Privacy Framework” means, as applicable, EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework, and/or the Swiss-U.S. Data Privacy Framework.
5. “Data Subject” means a natural person whose Personal Data is protected by Privacy Laws. For the avoidance of doubt, “Data Subject” includes the term “Consumer” under Privacy Laws.
6. “Data Subject Request” means a request from a Data Subject to exercise their rights over Personal Data afforded pursuant to Privacy Laws.
7. “EU SCCs” means standard contractual clauses approved by the European Commission in Commission Decision 2021/914 dated 4 June 2021, for transfers of personal data to countries not otherwise recognized as offering an adequate level of protection for personal data by the European Commission (as amended and updated from time to time), as modified by Section 9 of this DPA.
8. “ex-EEA Transfer” means the transfer of Personal Data subject to the GDPR from the European Economic Area (the “EEA”), to a country where the transfer is not governed by an adequacy decision made by the European Commission in accordance with the relevant provisions of the GDPR.
9. “ex-UK Transfer” means the transfer of Personal Data subject to Chapter V of the UK GDPR from outside the United Kingdom (the “UK”) where such transfer is not governed by an adequacy decision made by the Secretary of State in accordance with the relevant provisions of the UK GDPR and the Data Protection Act 2018.
10. “Personal Data” means any information provided to Company by or on behalf of Customer in connection with the Services that relates to an identified or identifiable Data Subject and constitutes “personal data,” “personal information,” or equivalent term under Privacy Laws.
11. “Privacy Laws” means any applicable laws and regulations in any relevant jurisdiction relating to the processing of Personal Data including, each to the extent applicable: (i) the General Data Protection Regulation (Regulation (EU) 2016/679) (“EU GDPR”) and the EU GDPR as it forms part of the law of England and Wales by virtue of section 3 of the European Union (Withdrawal) Act 2018 (the “UK GDPR”) (together, collectively, the “GDPR”), (ii) the Swiss Federal Act on Data Protection, (iii) the UK Data Protection Act 2018, (iv) the Privacy and Electronic Communications (EC Directive) Regulations 2003, (v) and U.S. state comprehensive privacy laws, such as the California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (the “CCPA”), and (; in each case, as updated, amended or replaced from time to time. The terms “affiliates,” “business purpose,” “Controller,” “Processor,” “process” or “processing,” “sell,” “share,” or “supervisory authority,” shall have the meanings set forth for those or equivalent terms under Privacy Laws. For the avoidance of doubt, the terms “Controller” and “Processor” include “Business” and “Service Provider,” respectively, as defined in the CCPA.
12. “Standard Contractual Clauses” means, as applicable, the EU SCCs and the UK SCCs.
13. “UK Addendum” means the template International Data Transfer Addendum issued by the Information Commissioner and laid before Parliament in accordance with s119A of the Data Protection Act 2018 on 2 February 2022 (as may be amended from time to time), as completed by Exhibit D.
14. “UK SCCs” means the EU SCCs, as amended by the UK Addendum.
Role of the Parties; Description of Processing.
1. Except as expressly set forth in this DPA or the Agreement, with respect to Personal Data, Customer is the Controller and Company is a Processor, or to the extent Customer is a Processor to a third-party Controller, Company is a subprocessor.
2. Company shall process Personal Data only (i) for purposes set forth in the Agreement, (ii) in a manner consistent with the documented instructions provided by Customer, which shall include the Agreement and this DPA, and (iii) as required by Privacy Laws or a supervisory authority; in such case, Company shall inform Customer of that legal requirement before processing to the extent legally permitted. The subject matter, nature, purpose, and duration of this processing, as well as the types of Personal Data collected and categories of Data Subjects involved, are described in Exhibit A to this DPA.
Customer’s Obligations. Customer shall, in its use of the Services, at all times process Personal Data, and provide instructions for the processing of Personal Data, in compliance with Privacy Laws. Customer shall ensure that the processing of Personal Data in accordance with Customer’s instructions will not cause Company to be in breach of the Privacy Laws. Customer is solely responsible for the accuracy, quality, and legality of (i) the Personal Data provided to Company by or on behalf of Customer, (ii) the means by which Customer acquired any such Personal Data, and (iii) the instructions it provides to Company regarding the processing of such Personal Data. Customer shall not provide or make available to Company any Personal Data in violation of the Agreement or otherwise inappropriate for the nature of the Services, and shall indemnify Company from all claims and losses in connection therewith. Company shall immediately notify Customer if an instruction, in Company’s opinion, infringes Privacy Laws or instruction of a supervisory authority.
Use of Personal Data. Company shall not: (i) sell or share Personal Data; (ii) retain, use, or disclose Personal Data outside of Company’s business relationship with Customer or for any purpose other for a business purpose under the CCPA on behalf of Customer or than as necessary to perform the Services for Customer pursuant to the Agreement, except as otherwise permitted in Agreement or by Privacy Laws; and (iii) combine Personal Data received from, or on behalf of, Customer with Personal Data that it receives from, or on behalf of, another party or person, except as necessary to provide the Services or as otherwise instructed by Customer.
Audit.
1. Company shall maintain records sufficient to demonstrate its compliance with its obligations under this DPA. Upon Customer’s written request at reasonable intervals, and subject to reasonable confidentiality controls, Company shall, either (i) make available for Customer’s review copies of certifications or reports demonstrating Company’s compliance with prevailing data security standards applicable to the processing of Personal Data, or (ii) if the provision of reports or certifications pursuant to (i) is not reasonably sufficient under Privacy Laws, allow Customer’s independent third party representative (that is reasonably acceptable to Company) to conduct an audit or inspection of Company’s data security infrastructure and procedures to help verify Company’s compliance with its obligations under Privacy Laws, provided that (a) Customer provides reasonable prior written notice of any such request for an audit and such inspection shall not be unreasonably disruptive to Company’s business; (b) such audit shall only be performed during business hours and occur no more than once per calendar year; (c) such audits will only occur pursuant to a mutually agreeable audit plan, (d) such audit shall be restricted to data relevant to Customer, and (e) such audits will not otherwise unreasonably interfere with Company’s operations. Notwithstanding the foregoing, Customer acknowledges that Company cannot authorize audits of its Authorized Subprocessors (but, if legally required, Company will use reasonable efforts to help Customer secure such rights). Customer shall be responsible for the costs of any such audits or inspections, including without limitation a reimbursement to Company for any time expended for on-site audits. If Customer and Company have entered into Standard Contractual Clauses as described in Section 9 (Transfers of Personal Data), the parties agree that the audits described in Clause 8.9 of the EU SCCs shall be carried out in accordance with this Section 5.1.
2. To the extent permitted under Privacy Laws, if Customer determines that Company is processing Personal Data in an unauthorized manner, Customer may, taking into account nature of Company’s processing and the nature of the Personal Data processed by Company on behalf of Customer, and upon providing prior written notice, take commercially reasonable and appropriate steps to stop and remediate such unauthorized processing as set forth in this DPA.
Authorized Subprocessors.
1. Customer provides general written authorization to Company to engage subprocessors as necessary to perform the Services. On the Effective Date, Company uses the Authorized Subprocessors listed in Exhibit B to this DPA (“List”). If Company intends to engage a new Authorized Subprocessor it will provide ten (10) days email notice. Customer may object within such period or approval is granted. If Customer reasonably objects within such period, the parties will discuss the issue diligently and in good faith. If they cannot agree on a workaround or alternative within another ten (10) days then Customer may, as its sole remedy, terminate the Agreement on prompt written notice. Termination shall not relieve Customer of any fees owed to Company under the Agreement and no refunds will be provided.
2. Company will enter into a written agreement with the Authorized Subprocessor imposing on the Authorized Subprocessor data protection obligations consistent with those imposed on Company under this DPA with respect to the protection of Personal Data. In case an Authorized Subprocessor fails to fulfill its data protection obligations under such written agreement with Company, Company will remain liable to Customer for the performance of the Authorized Subprocessor’s obligations under such agreement.
3. Company will provide Customer with copies of the applicable agreements with Authorized Subprocessors on request (but may redact information not relevant for this DPA (such as financial terms) or that Company otherwise deems highly sensitive).
Confidentiality; Security of Personal Data.
1. Company shall ensure that any person it authorizes to process Personal Data has agreed to protect Personal Data in accordance with Company’s confidentiality obligations in the Agreement. Customer agrees that Company may disclose Personal Data to its advisers, auditors or other third parties as reasonably required in connection with the performance of its obligations under this DPA, the Agreement, or the provision of Services to Customer.
2. Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, Company shall maintain appropriate technical and organizational measures to ensure a level of security appropriate to the risk of processing Personal Data, as described in Exhibit C.
Personal Data Breach.
1. In the event of a Personal Data Breach, Company shall inform Customer of the Personal Data Breach within forty-eight (48) hours from discovery and take such steps as Company in its sole discretion deems necessary and reasonable to remediate such Personal Data Breach, to the extent that remediation is within Company’s reasonable control.
2. In the event of a Personal Data Breach, Company shall, taking into account the nature of the processing and the information available to Company, provide Customer with reasonable cooperation and assistance necessary for Customer to comply with its obligations under Privacy Laws with respect to notifying (i) the relevant supervisory authority or regulatory agency and (ii) Data Subjects affected by such Personal Data Breach without undue delay.
3. The obligations described in Sections 8.1 and 8.2 shall not apply in the event that a Personal Data Breach results from the actions or omissions of Customer. Company’s obligation to report or respond to a Personal Data Breach under Sections 8.1 and 8.2 will not be construed as an acknowledgement by Company of any fault or liability with respect to the Personal Data Breach.
Transfers of Personal Data.
1. The parties agree that Company may transfer Personal Data processed under this DPA outside the EEA, the UK, or Switzerland as necessary to provide the Services. Customer acknowledges that Company’s primary processing operations take place in the United States, and that the transfer of Personal Data to the United States is necessary for the provision of the Services to Customer. If Company transfers Personal Data protected under this DPA to a jurisdiction for which the European Commission has not issued an adequacy decision, Company will ensure that appropriate safeguards have been implemented for the transfer of Personal Data in accordance with Privacy Laws.
2. Ex-EEA Transfers. The Parties agree that ex-EEA Transfers shall either be made pursuant to (i) the Data Privacy Framework to the extent the recipient of the ex-EEA Transfer is certified accordingly, or (ii) the EU SCCs, which are deemed entered into (and incorporated herein by reference) and completed as follows:
  1. Module One (Controller to Controller) of the EU SCCs applies when Company is processing Personal Data as a controller pursuant to Section 9 of this DPA.
  2. Module Two (Controller to Processor) of the EU SCCs applies when Customer is a controller and Company is a processor of Personal Data in accordance with Section 2 of this DPA.
  3. Module Three (Processor to Subprocessor) of the EU SCCs applies when Customer is a processor and Company is a subprocessor of Personal Data in accordance with Section 2 of this DPA.
3. For each module, where applicable the following applies:
  1. The optional docking clause in Clause 7 does not apply.
  2. In Clause 9, Option 2 (general authorization) applies, and the minimum time period for prior notice of subprocessor changes shall be as set forth in Section 6.1 of this DPA.
  3. In Clause 11, the optional language does not apply.
  4. All square brackets in Clause 13 are hereby removed.
  5. In Clause 17 (Option 1), the EU SCCs will be governed by the laws of the Republic of Ireland.
  6. In Clause 18(b), disputes will be resolved before the courts of the Republic of Ireland.
  7. Exhibit B to this DPA contains the information required in Annex I of the EU SCCs.
  8. Exhibit C to this DPA contains the information required in Annex II of the EU SCCs,
  9. By entering into this DPA, the Parties are deemed to have signed the EU SCCs incorporated herein, including their Annexes.
4. Ex-UK Transfers. The Parties agree that ex-UK Transfers shall either be made pursuant to (i) the Data Privacy Framework to the extent that recipient of the ex-UK Transfer is certified accordingly, or (ii) the UK SCCs, which are deemed entered into and incorporated herein by reference. The UK Addendum (including the EU SCCs incorporated into it) is (1) governed by the laws of England and Wales and (2) any dispute arising from it is resolved by the courts of England and Wales.
5. Transfers from Switzerland. The Parties agree that transfers from Switzerland shall either be made pursuant to (i) the Data Privacy Framework to the extent that recipient of the transfer from Switzerland is certified accordingly, or (ii) the EU SCCs with the following modifications:
  1. The terms “General Data Protection Regulation” or “Regulation (EU) 2016/679” as utilized in the EU SCCs shall be interpreted to include the Federal Act on Data Protection of 19 June 1992 (the “FADP,” and as revised as of 25 September 2020, the “Revised FADP”) with respect to data transfers subject to the FADP.
  2. Clause 13 of the EU SCCs is modified to provide that the Federal Data Protection and Information Commissioner (“FDPIC”) of Switzerland shall have authority over data transfers governed by the FADP and the appropriate EU supervisory authority shall have authority over data transfers governed by the GDPR. Subject to the foregoing, all other requirements of Clause 13 shall be observed.
  3. The term “EU Member State” as utilized in the EU SCCs shall not be interpreted in such a way as to exclude Data Subjects in Switzerland from exercising their rights in their place of habitual residence in accordance with Clause 18(c) of the EU SCCs.
6. Supplementary Measures. In respect of any transfer of Personal data made pursuant to the Standard Contractual Clauses, the following supplementary measures shall apply:
  1. As of the date of this DPA, Company has not received any formal legal requests from any government intelligence or security service/agencies in the country to which the Personal Data is being exported, for access to (or for copies of) such Personal Data (“Government Agency Requests”).
  2. If Company receives a Government Agency Request, Company shall attempt to redirect the government agency to Customer. As part of this effort, Company may provide Customer’s basic contact information to the government agency. If Company is compelled to disclose Personal Data, to the extent legally permitted, Company shall notify Customer of the demand and reasonably cooperate to allow Customer to seek a protective order or other appropriate remedy. Company shall not voluntarily disclose Personal Data to any law enforcement or government agency. The Parties shall determine whether all or any transfers of Personal Data pursuant to this DPA should be suspended in the light such a Government Agency Request.
  3. The Parties will confer as appropriate to consider whether: (i) the protection afforded by the laws of the country of Company to data subjects whose Personal Data is being transferred is sufficient to provide broadly equivalent protection to that afforded in the EEA or the UK, as applicable; (ii) additional measures are reasonably necessary for the transfer to comply with Privacy Laws; and (iii) it is still appropriate for Personal Data to be transferred to the relevant Company, taking into account all relevant information available, including guidance by supervisory authorities, to the Parties.
  4. If either (i) any of the means of legitimizing a transfer cease to be valid or (ii) any supervisory authority requires transfers of Personal Data pursuant to those means to be suspended, the Parties agree to amend the means of legitimizing transfers in accordance with Privacy Laws. To the extent necessary to ensure the enforceability of the Standard Contractual Clauses, the Parties shall execute the Standard Contractual Clauses as a separate agreement.
Data Protection Assessments. Taking into account the nature of Company’s processing and the information available to Company, Company shall reasonably cooperate with Customer to conduct any data protection or privacy impact assessments as required by Privacy Laws, including by providing Customer with information and documents necessary for such assessments that Customer cannot otherwise obtain without Company’s assistance.
Data Subject Request.
Company shall, to the extent permitted by Privacy Laws, notify Customer upon receipt of a Data Subject Request. If Company receives a Data Subject Request in relation to Personal Data, Company will advise the Data Subject to submit their request to Customer and Customer will be responsible for responding to such request, including, where necessary, by using the functionality of the Services. Customer is solely responsible for ensuring that Data Subject Requests communicated to Company, and, if applicable, for ensuring that a record of consent to processing is maintained with respect to each Data Subject.
Company shall, at the request of Customer, and taking into account the nature of the processing applicable to any Data Subject Request, apply appropriate technical and organizational measures to assist Customer in complying with Customer’s obligation to respond to such Data Subject Request and/or in demonstrating such compliance, where possible, provided that (i) Customer is itself unable to respond without Company’s assistance and (ii) Company is able to do so in accordance with all applicable laws, rules, and regulations. Customer shall be responsible to the extent legally permitted for any costs and expenses arising from any such assistance by Company.
Return or Destruction of Personal Data. Upon the termination or expiration of the Agreement, at Customer’s choice, Company shall return or delete Personal Data, unless further storage of such Personal Data is required or authorized by applicable law. If return or destruction is impracticable or prohibited by law, rule or regulation, Company shall take measures to block such Personal Data from any further processing (except to the extent necessary for its continued hosting or processing required by law, rule or regulation) and shall continue to appropriately protect the Personal Data remaining in its possession, custody, or control. If Customer and Company have entered into Standard Contractual Clauses as described in Section 9 (Transfers of Personal Data), the parties agree that the certification of deletion of Personal Data that is described in Clause 8.1(d) and Clause 8.5 of the EU SCCs (as applicable) shall be provided by Company to Customer only upon Customer’s request.
Company’s Role as a Controller. The parties acknowledge and agree that with respect to Company Account Data and Company Usage Data, Company is an independent controller, not a joint controller with Customer. Company will process Company Account Data and Company Usage Data as a controller (i) to manage the relationship with Customer; (ii) to carry out Company’s core business operations, such as accounting, audits, tax preparation and filing and compliance purposes; (iii) to monitor, investigate, prevent and detect fraud, security incidents and other misuse of the Services, and to prevent harm to Customer; (iv) for identity verification purposes; (v) to comply with legal or regulatory obligations applicable to the processing and retention of Personal Data to which Company is subject; and (vi) as otherwise permitted under Privacy Laws and in accordance with this DPA and the Agreement. Company may also process Company Usage Data as a controller to provide, optimize, and maintain the Services, to the extent permitted by Privacy Laws. Any processing by Company as a controller shall be in accordance with Company’s privacy policy.

Exhibit A

Details of Processing

Nature and Purpose of Processing: Company will process Personal Data as necessary to provide the Services under the Agreement, for the purposes specified in the Agreement and this DPA, and in accordance with Customer’s instructions as set forth in this DPA.

Duration of Processing: During the term of the Agreement (and any wind-down – unless earlier return is requested).

Categories of Data Subjects: Customer end-users/customers and/or Customer employees

Categories of Personal Data: Company processes Personal Data contained in Company Account Data, Company Usage Data, and any Personal Data provided by Customer (including any Personal Data Customer collects from its end users and processes through its use of the Services) or collected by Company in order to provide the Services or as otherwise set forth in the Agreement or this DPA. Categories of Personal Data include name, location, email address, phone number, address, occupation, and title, as well as telemetry data from the agent installed on Company endpoints. This includes systems and user information (e.g., name, email address, IP Address).

Sensitive Data or Special Categories of Data: None.

Exhibit B

The following includes the information required by Annex I and Annex III of the EU SCCs, and Table 1, Annex 1A, and Annex 1B of the UK Addendum.

1. The Parties

Data exporter(s): [Identity and contact details of the data exporter(s) and, where applicable, of its/their data protection officer and/or representative in the European Union]

Name: Customer

Address: As designed in the Agreement.

Contact person’s name, position and contact details: As designed in the Agreement.

Activities relevant to the data transferred under these Clauses: As provided in Section 2 of this DPA.

Signature and date: By entering into the Agreement, Customer is deemed to have signed these Standard Contractual Clauses incorporated herein, as of the Effective Date of the Agreement.

Role (controller/processor): As provided in Section 2 of this DPA.

Data importer(s): [Identity and contact details of the data importer(s), including any contact person with responsibility for data protection]

Name: Company

Address: As designed in the Agreement.

Contact person’s name, position and contact details: As designed in the Agreement.

Activities relevant to the data transferred under these Clauses: As provided in the Agreement or DPA

Signature and date: By entering into the Agreement, Company is deemed to have signed these Standard Contractual Clauses incorporated herein, as of the Effective Date of the Agreement

Role (controller/processor): As provided in Section 2 of this DPA.‍

2. Description of the Transfer

Data Subjects	As described in Exhibit A
Categories of Personal Data	As described in Exhibit A
Special Category Personal Data (if applicable)	As described in Exhibit A
Nature of the Processing	As described in Exhibit A
Purposes of Processing	As described in Exhibit A
Duration of Processing and Retention (or the criteria to determine such period)	As described in Exhibit A
Frequency of the transfer	As necessary to provide perform all obligations and rights with respect to Personal Data as provided in the Agreement or DPA
Recipients of Personal Data Transferred to the Data Importer	As provided below

3. Competent Supervisory Authority

The supervisory authority shall be the supervisory authority of the Data Exporter, as determined in accordance with Clause 13 of the EU SCCs. The supervisory authority for the purposes of the UK Addendum shall be the UK Information Commissioner’s Officer.

4. List of Authorized Subprocessors

Subprocessor	Purpose / Role	Data Types Handled	Location / Region
Amazon Web Services (AWS)	Core infrastructure / cloud service provider (compute, storage, databases)	Customer data, logs, application data	United States (us-east-1, us-west-2)
Amazon Web Services Bedrock (LLM Providers)	AI providers	customer data, logs, application data	United States
Arize	LLM observability	Customer data, logs, application data	United States
ClickHouse	Columnar database for real-time analytics and big data processing (detection results)	Customer data, detection results	United States
GitHub	Version control and collaboration platform	Application data	United States
Google Workspace	Identity provider	Internal data	United States
Grafana	Monitoring, alerting, and notification services for the Nebulock Inc. platform	Application metadata, telemetry, dashboards based on customer data	GCP us-central-1
Notion	Productivity and collaboration tool	Internal documentation data	United States
Posthog	User analytics	Product and usage analytics	United States
Linear	Project management tool	Internal task tracking and customer requests	United States
Pylon	Customer support platform	Manages customer contact information and contents of support communications	United States
Slack	Internal communication and alerting (may include indirect data references)	Internal metadata, alert summaries	AWS US
Stytch	Authentication and identity management (APIs for user authentication)	Customer and application data	AWS US
Synqly	Provides a subset of integrations between customers and Nebulock	Customer data that has these integrations configured	US
Tavily by Nebius	Real-time web search and content retrieval for AI agents	Customer data, application data	US
Vanta	Trust management platform	internal data	US

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Exhibit C

Description of the Technical and Organisational Security Measures implemented by the Data Importer‍

Security Measures	Responsibility for implementation and management: Processor
Measures for ensuring ongoing confidentiality, integrity, availability of data	Company maintains a reasonable security program to support regulatory compliance, preserve customer trust, and safeguard the security, privacy, confidentiality, integrity, and availability of systems processing confidential information. Company maintains SOC 2 type II. All Company employees must review and sign an Acceptable Use Policy and undergo security and data privacy training upon hire and at least annually thereafter. Company performs background and/or reference checks for all new hires according to local laws and regulations as a condition of hire.
Measures of pseudonymization and encryption of personal data	We encrypt all Company issued employee computers with the full disk encryption offered by the operating system used. We encrypt all customer uploaded data and login credentials in transit. All communication with the Company products occurs over HTTPS. Our products support TLS 1.2 and 1.3. Customer uploaded data and related backups are encrypted at rest using Server-Side Encryption, with Amazon S3-Managed Keys (SSE-S3) or Amazon KMS-Managed Keys (SSE-KMS). Additionally, all data in Company’s products are encrypted at rest. Pseudonymization may be used for some use-cases, where required by the technical setup or classification of data.
Measures for ensuring resilience of processing systems and services	Company does not rely on physical locations to provide services, therefore our exposure to most threats of disaster is minimal. However, we do have an extensive business continuity policy and incident response procedure in place. This policy includes established roles for incident response and an emergency response team made up of high-level employees from across the organization and our geographic locations. We have a formal security risk program, asset management and detection systems in place.
Measures for ensuring the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident	Our products are across multiple availability zones and our databases live in multiple availability zones. Engineering teams run backup restoration tests for critical services at least annually. We have also implemented an on-call rotation to ensure 24/7 coverage of our systems in the event of an incident.
Processes for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures in order to ensure the security of the processing	Company maintains a comprehensive security program to support regulatory compliance, preserve customer trust, and safeguard the security, privacy, confidentiality, integrity, and availability of systems processing confidential information. We engage third parties to audit our adherence to these standards at least annually. We perform internal audits as part of the Security program. We follow quality protocols during the development, testing, and deployment of our software updates. We also incorporate pen testing performed by a third party and testing of the products security controls.
Measures for user identification and authorization	We have a formal access provisioning/deprovisioning lifecycle, which includes on, off-boarding as well as role change. We conduct at-minimum semi-annual access reviews to ensure erroneous access provisioning is identified.
Measures for the protection of data during transmission	We encrypt customer uploaded data in storage. Data that leaves our systems (whether physical or virtual) is encrypted. We encrypt all customer uploaded data and login credentials in transit. All communication with the Company products occurs over HTTPS. Our products support TLS 1.2 and 1.3.
Measures for the protection of data during storage	We encrypt customer uploaded data in storage. Data that leaves our systems (whether physical or virtual) is encrypted. We encrypt all Company issued employee computers with the full disk encryption offered by the operating system used. Windows machines use Bit locker, Apple devices use Filevault 2, and Linux devices use dm-crypt with LUKS. Customer uploaded data and related backups are encrypted at rest using Server-Side Encryption with Amazon S3-Managed Keys (SSE-S3).
Measures for ensuring physical security of locations at which personal data are processed	Company does not rely on physical locations to process customer data. However, we have implemented a series of controls to manage physical access to our offices. Where possible, our offices have personnel assigned to monitor access. All Company employees have keycards to access offices. The different components of the Company product suite are hosted across a variety of services in order to take advantage of the benefits of different classes of infrastructure and ensure continuous, uninterrupted availability of the platform. AWS is held to the same standards we hold ourselves, and we assess their security practices annually. Company uses Amazon Web Services (AWS) as the cloud service provider for the product infrastructure. Though AWS has a variety of acknowledged security certifications Company has built a security program to cover our areas of the shared responsibility model utilized by cloud service providers.
Measures for ensuring events logging	Server logs are shipped to a central logging service. Logs are retained for up to 12 months, depending on their purpose.
Measures for ensuring system configuration, including default configuration	All systems are patched regularly. A firewall or similar is in place. We have patch management and vulnerability policy that we adhere to. Company servers are managed via configuration management software, and changes to configuration standards are monitored and audited periodically.
Measures for internal IT and IT security governance and management	Company maintains a comprehensive security program to support regulatory compliance, preserve customer trust, and safeguard the security, privacy, confidentiality, integrity, and availability of systems processing confidential information. The Company security team is staffed by dedicated professionals reporting directly to executive management. We use MFA/2FA on all applications that contain personal data and production access. All employees receive training on this during onboarding.
Measures for certification/assurance of processes and products	Company maintains a comprehensive security program to support regulatory compliance, preserve customer trust, and safeguard the security, privacy, confidentiality, integrity, and availability of systems processing confidential information. The Company security team is staffed by dedicated professionals reporting directly to executive management.
Measures for ensuring data minimisation	Company is compliant with the GDPR and CCPA/CPRA. Company is headquartered in the US and has centralized its global privacy compliance with the GDPR. Given that the GDPR is a more comprehensive privacy framework than the CCPA, CPRA, and most other global privacy laws we look for differences in the laws to ensure compliance while maintaining the GDPR at the core.
Measures for ensuring data quality	We follow a strict quality protocol during the development, testing, and deployment of our software updates. We also incorporate user testing whenever possible to ensure that our product most accurately meets the needs of our customers. Engineers follow documented secure-by-design principles, privacy-by-design standards, secure coding guidelines, and formal code review procedures throughout the software development lifecycle.
Measures for ensuring limited data retention	Unless otherwise noted in your contract, if you terminate your contract with Company, we will retain your data for a maximum of 30 days. After the 30-day window, except for any information that we are legally required to retain, an automated process deletes or permanently anonymizes all data in the platform related to the expired contract.
Measures for ensuring accountability	Annual third-party audits, as well as frequent internal audits by both the Privacy and the Security team.

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Exhibit D

UK Addendum

International Data Transfer Addendum to the EU Commission Standard Contractual Clauses

Part 1: Tables

Table 1: Parties

The Parties	Exporter	Importer
Start Date	This UK Addendum shall have the same effective date as the DPA
Parties’ Details	Customer	Company
Key Contact	See Exhibit B of this DPA	See Exhibit B of this DPA

Table 2: Selected SCCs, Modules and Selected Clauses

EU SCCs	The Version of the Approved EU SCCs which this UK Addendum is appended to as defined in the DPA and completed by Section 9.2 and 9.3 of the DPA.

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Table 3: Appendix Information

Annex 1A: List of Parties	As per Table 1 above
Annex 1B: Description of Transfer	See Exhibit B of this DPA
Annex II: Technical and organisational measures including technical and organisational measures to ensure the security of the data:	See Exhibit C of this DPA
Annex III: List of Sub processors (Modules 2 and 3 only):	See Exhibit B of this DPA

Table 4: Ending this UK Addendum when the Approved UK Addendum Changes

Ending this UK Addendum when the Approved UK Addendum changes	Selected: Importer Selected: Exporter Not selected: Neither Party

Part 2: Mandatory Clauses

The Mandatory Clauses of the UK Addendum are incorporated herein by reference.