Data Processing Addendum

This Data Processing Addendum ("DPA") supplements the Terms of Service (the "Agreement") entered into by and between the customer signing this DPA ("Customer") and Chatzuri.co, Inc. ("Company"). By executing the DPA in accordance with Section 11 herein, Customer enters into this DPA on behalf of itself and, to the extent required under applicable Data Protection Laws (defined below), in the name and on behalf of its Affiliates (defined below), if any.

This DPA incorporates the terms of the Agreement, and any terms not defined in this DPA shall have the meaning set forth in the Agreement.

Definitions
1. "Affiliate" means:
  1. iAn entity of which a party directly or indirectly owns fifty percent (50%) or more of the stock or other equity interest
  2. iiAn entity that owns at least fifty percent (50%) or more of the stock or other equity interest of a party
  3. iiiAn entity which is under common control with a party by having at least fifty percent (50%) or more of the stock or other equity interest of such entity and a party owned by the same person, but such entity shall only be deemed to be an Affiliate so long as such ownership exists.
2. "Authorized Sub-Processor" means a third-party who has a need to know or otherwise access Customer's Personal Data to enable Company to perform its obligations under this DPA or the Agreement, and who is either:
  1. ilisted in Exhibit B or
  2. isubsequently authorized under Section 4.2 of this DPA.
3. "Customer Data" means any 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. Company Account Data also includes any data Company may need to collect for the purpose of managing its relationship with Customer, identity verification, or as otherwise required by applicable laws and regulations.
4. "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 data used to optimize and maintain performance of the Services, and to investigate and prevent system abuse.
5. "Data Exporter" means Customer.
6. "Data Importer" means Company.
7. "Data Protection Laws" means any applicable laws and regulations in any relevant jurisdiction relating to the use or processing of Personal Data including:
  1. ithe California Consumer Privacy Act ("CCPA")
  2. ii 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")
  3. iii the Swiss Federal Act on Data Protection
  4. ivthe UK Data Protection Act 2018
  5. vthe Privacy and Electronic Communications (EC Directive) Regulations 2003
  in each case, as updated, amended or replaced from time to time. The terms "Data Subject", "Personal Data", "Personal Data Breach", "processing", "processor," "controller," and "supervisory authority" shall have the meanings set forth in the GDPR.
8. "EU SCCs" means the 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 6.2 of this DPA.
9. "ex-EEA Transfer" means the transfer of Personal Data, which is processed in accordance with the GDPR, from the Data Exporter to the Data Importer (or its premises) outside the European Economic Area (the "EEA"), and such transfer is not governed by an adequacy decision made by the European Commission in accordance with the relevant provisions of the GDPR.
10. "ex-UK Transfer" means the transfer of Personal Data covered by Chapter V of the UK GDPR, which is processed in accordance with the UK GDPR and the Data Protection Act 2018, from the Data Exporter to the Data Importer (or its premises) outside the United Kingdom (the "UK"), and 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.
11. "Services" shall have the meaning set forth in the Agreement.
12. "Standard Contractual Clauses" means the EU SCCs and the UK SCCs.
13. "UK SCCs" means the EU SCCs, as amended by the UK Addendum.
Relationship of the Parties; Processing of Data
1. The parties acknowledge and agree that with regard to the processing of Personal Data, Customer may act either as a controller or processor and, except as expressly set forth in this DPA or the Agreement, Company is a processor. 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 Data Protection 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 Data Protection Laws. Customer is solely responsible for the accuracy, quality, and legality of:
  1. ithe Personal Data provided to Company by or on behalf of Customer
  2. iithe means by which Customer acquired any such Personal Data
  3. iiithe 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.
2. Company shall not process Personal Data:
  1. ifor purposes other than those set forth in the Agreement and/or Exhibit A
  2. iiin a manner inconsistent with the terms and conditions set forth in this DPA or any other documented instructions provided by Customer, including with regard to transfers of personal data to a third country or an international organization, unless required to do so by Supervisory Authority to which the Company is subject; in such a case, the Company shall inform the Customer of that legal requirement before processing, unless that law prohibits such information on important grounds of public interest
  3. iiiin violation of Data Protection Laws.
  Customer hereby instructs Company to process Personal Data in accordance with the foregoing and as part of any processing initiated by Customer in its use of the Services.
3. The subject matter, nature, purpose, and duration of this processing, as well as the types of Personal Data collected and categories of Data Subjects, are described in Exhibit A to this DPA.
4. Following completion of the Services, at Customer's choice, Company shall return or delete Customer's 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 6 (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.
5. CCPA. Except with respect to Company Account Data and Company Usage Data, the parties acknowledge and agree that Company is a service provider for the purposes of the CCPA (to the extent it applies) and is receiving personal information from Customer in order to provide the Services pursuant to the Agreement, which constitutes a business purpose. Company shall not sell any such personal information. Company shall not retain, use or disclose any personal information provided by Customer pursuant to the Agreement except as necessary for the specific purpose of performing the Services for Customer pursuant to the Agreement, or otherwise as set forth in the Agreement or as permitted by the CCPA. The terms "personal information," "service provider," "sale," and "sell" are as defined in Section 1798.140 of the CCPA. Company certifies that it understands the restrictions of this Section 2.5
Confidentiality
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.
Authorized Sub-Processors
1. Customer acknowledges and agrees that Company may
  1. iengage its Affiliates as well as the Authorized Sub-Processors on the List (defined below) to access and process Personal Data in connection with the Services and
  2. iifrom time to time engage additional third parties for the purpose of providing the Services, including without limitation the processing of Personal Data.
  By way of this DPA, Customer provides general written authorization to Company to engage sub-processors as necessary to perform the Services.
2. Company will provide a mechanism to subscribe to notifications (which may include but are not limited to email notifications) of new Authorized Sub-Processors and Customer, if it wishes, will subscribe to such notifications where available. If Customer does not subscribe to such notifications, Customer waives any right it may have to receive prior notice of changes to Authorized Sub-Processors. At least ten (10) days before enabling any third party other than existing Authorized Sub-Processors to access or participate in the processing of Personal Data, Company will add such third party to the List and notify subscribers, including Customer, via the aforementioned notifications. Customer may object to such an engagement by informing Company in writing within ten (10) days of receipt of the aforementioned notice by Customer, provided such objection is in writing and based on reasonable grounds relating to data protection. Customer acknowledges that certain sub-processors are essential to providing the Services and that objecting to the use of a sub-processor may prevent Company from offering the Services to Customer
3. If Customer reasonably objects to an engagement in accordance with Section 4.2, and Company cannot provide a commercially reasonable alternative within a reasonable period of time, Customer may discontinue the use of the affected Service by providing written notice to Company. Discontinuation shall not relieve Customer of any fees owed to Company under the Agreement.
4. If Customer does not object to the engagement of a third party in accordance with Section 4.2 within ten (10) days of notice by Company, that third party will be deemed an Authorized Sub-Processor for the purposes of this DPA.
5. Company will enter into a written agreement with the Authorized Sub-Processor imposing on the Authorized Sub-Processor data protection obligations comparable to those imposed on Company under this DPA with respect to the protection of Personal Data. In case an Authorized Sub-Processor 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 Sub-Processor's obligations under such agreement.
6. If Customer and Company have entered into Standard Contractual Clauses as described in Section 6 (Transfers of Personal Data),
  1. ithe above authorizations will constitute Customer's prior written consent to the subcontracting by Company of the processing of Personal Data if such consent is required under the Standard Contractual Clauses, and
  2. iithe parties agree that the copies of the agreements with Authorized Sub-Processors that must be provided by Company to Customer pursuant to Clause 9(c) of the EU SCCs may have commercial information, or information unrelated to the Standard Contractual Clauses or their equivalent, removed by the Company beforehand, and that such copies will be provided by the Company only upon request by Customer.
Security of Personal Data
1. 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.Exhibit C sets forth additional information about Company's technical and organizational security measures.
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 Customer's 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 Data Protection Laws
2. Ex-EEA Transfers. The parties agree that ex-EEA Transfers are made pursuant to the EU SCCs, which are deemed entered into (and incorporated into this DPA by this reference) and completed as follows:
  1. iModule One (Controller to Controller) of the EU SCCs apply when Company is processing Personal Data as a controller pursuant to Section 9 of this DPA.
  2. iModule Two (Controller to Processor) of the EU SCCs apply when Customer is a controller and Company is processing Personal Data for Customer as a processor pursuant to Section 2 of this DPA.
  3. iModule Three (Processor to Sub-Processor) of the EU SCCs apply when Customer is a processor and Company is processing Personal Data on behalf of Customer as a sub-processor.
3. For each module, where applicable the following applies:
  1. iThe optional docking clause in Clause 7 does not apply.
  2. iiIn Clause 9, Option 2 (general written authorization) applies, and the minimum time period for prior notice of sub-processor changes shall be as set forth in Section 4.2 of this DPA;
  3. iiiIn Clause 11, the optional language does not apply;
  4. ivAll square brackets in Clause 13 are hereby removed;
  5. vIn Clause 17 (Option 1), the EU SCCs will be governed by Ireland law.
  6. viIn Clause 18(b), disputes will be resolved before the courts of Ireland;
  7. viiExhibit B to this DPA contains the information required in Annex I and Annex III of the EU SCCs;
  8. viiiExhibit C to this DPA contains the information required in Annex II of the EU SCCs; and
  9. ixBy 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 are made pursuant to the UK SCCs, which are deemed entered into and incorporated into this DPA by reference, and amended and completed in accordance with the UK Addendum, which is incorporated herein as Exhibit D of this DPA
5. Transfers from Switzerland. The parties agree that transfers from Switzerland are made pursuant to the EU SCCs with the following modifications:
  1. iThe 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. iiThe terms of the EU SCCs shall be interpreted to protect the data of legal entities until the effective date of the Revised FADP.
  3. iiiClause 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 Section 13 shall be observed.
  4. iiiThe 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. Government Agency Requests and Data Transfer Safeguards:
  1. 1Current Status: As of the effective date of this DPA, the Data Importer confirms it has not received any formal legal requests from government intelligence or security agencies in the destination country for access to Customer's Personal Data ("Government Agency Requests" ).
  2. 2
    Request Handling Protocol: Should Government Agency Requests be received post-DPA execution:
    The Data Importer will attempt to redirect authorities to request data directly from Customer
    May provide Customer's basic contact information to facilitate direct communication
    If legally compelled to disclose, will provide Customer with reasonable notice (unless prohibited by law) and cooperate in seeking protective measures
    No voluntary disclosures will be made to government agencies
  3. 3
    Transfer Assessment: Both parties will promptly convene to evaluate:
    Whether the destination country's laws provide essentially equivalent protection to EEA/UK standards
    Necessity of supplemental safeguards for compliance with Data Protection Laws
    Continued appropriateness of transfers considering all relevant circumstances and regulatory guidance
  4. 4
    Legal Framework Adaptation: Where Data Protection Laws require:
    The Data Importer will promptly execute Standard Contractual Clauses (SCCs) with modifications reflecting transfer specifics and legal requirements
    If existing transfer mechanisms become invalid or are suspended by authorities, the Data Importer may implement alternative compliant arrangements with notice
Rights of Data Subjects
1. Data Subject Request Handling:
  1. 1
    Notification Obligation: Company shall, to the extent permitted by law, notify Customer upon receipt of a Data Subject Request to exercise rights of:
    Access
    Rectification
    Erasure ("right to be forgotten")
    Data portability
    Restriction or cessation of processing
    Withdrawal of consent
    Objection to automated decision-making
  2. 2
    Request Redirection: When Company receives a Data Subject Request regarding Customer's data:
    Company will instruct the Data Subject to submit their request directly to Customer
    Customer bears sole responsibility for responding to such requests
    Customer must use Service functionality where applicable
  3. 3
    Customer Responsibilities: Customer must:
    Ensure erasure, restriction, or consent withdrawal requests are properly communicated to Company
    Maintain records of consent where applicable
    Cover all reasonable costs for Company's assistance (where legally permitted)
  4. 4
    Limited Assistance: Company will provide technical and organizational assistance to help Customer comply with Data Subject Requests when:
    Customer cannot respond without Company's support
    Company can legally provide such assistance
    The nature of processing makes assistance feasible
    Note: All assistance is subject to applicable laws, rules, and regulations.
Actions and Access Requests; Audits
1. Compliance Assistance & Audit Rights:
  1. 1
    DPIA Assistance: Company shall provide reasonable cooperation to assist Customer with:
    Data Protection Impact Assessments (DPIAs) under GDPR
    Demonstrating compliance with GDPR obligations
    Limited to situations where Customer lacks access to relevant information
    Customer bears reasonable costs of such assistance
  2. 2
    Regulatory Cooperation: Company shall assist Customer with:
    Supervisory Authority consultations
    Regulatory cooperation required by GDPR
    Subject to nature of processing and information availability
  3. 3
    Record Keeping:
    Company maintains compliance records for 3 years post-termination
    Customer may review/audit records during business hours with notice
  4. 4
    Audit Rights:
    Upon request, Company provides:
    Compliance certifications/reports or
    Third-party audit access if reports are insufficient
    Audit conditions:
    Annual limit (1 audit/calendar year)
    Reasonable notice & business hours only
    Limited to Customer-relevant data
    Minimal business disruption
    Customer bears all audit costs
    For SCCs under Section 6, audits follow Clause 8.9 of EU SCCs
  5. 5
    Legal Compliance Notice: Company will notify Customer if instructions appear to violate:
    Data Protection Laws
    Supervisory Authority requirements
  6. 6
    Breach Notification:
    Company shall:
    Notify Customer without undue delay
    Take reasonable remediation steps
    Exclusions:
    Breaches caused by Customer actions/omissions
    Notification doesn't constitute fault admission
  7. 7
    Breach Cooperation: Company shall assist Customer with:
    Supervisory Authority notifications
    Data Subject communications
    GDPR compliance obligations
    Considering nature of processing and available information
Company's Role as a Controller.
1. Controller Responsibilities:
  1. 1
    Controller Status: The parties acknowledge that:
    For Company Account Data and Company Usage Data, Company acts as an independent controller
    No joint controller relationship exists for these data types
  2. 2
    Processing Purposes: As controller, Company processes data for:
    Managing the customer relationship
    Core business operations:
    Accounting & audits
    Tax preparation & filing
    Compliance purposes
    Security monitoring:
    Fraud prevention/detection
    Security incident investigation
    Service misuse prevention
    Identity verification
    Legal/regulatory compliance
    Other lawful purposes under Data Protection Laws
  3. 3
    Service Optimization: Company may process Usage Data to:
    Provide, maintain, and improve Services
    Optimize service performance
    When permitted by Data Protection Laws
  4. 4
    Privacy Policy: All controller processing is governed by:
    Company's Privacy Policy available at: https://www.chatzuri.com/privacy-policy
    Terms of this DPA
    The main Agreement
Conflict
1. In the event of any conflict or inconsistency among the following documents, the order of precedence will be:
  1. ithe applicable terms in the Standard Contractual Clauses;
  2. iithe terms of this DPA;
  3. iithe Agreement; and
  4. iithe Company's privacy policy. and
  Any claims brought in connection with this DPA will be subject to the terms and conditions, including, but not limited to, the exclusions and limitations set forth in the Agreement.

Exhibit A

Details of Processing

1Nature and Purpose of Processing

Company will process Customer's 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. The nature of processing includes, without limitation:

Receiving data, including collection, accessing, retrieval, recording, and data entry
Protecting data, including restricting, encrypting, and security testing
Holding data, including storage, organization, and structuring
Erasing data, including destruction and deletion
Analyzing data, including product usage assessment
Sharing data, including disclosure to subprocessors as permitted in this DPA

2Duration of Processing

Company will process Customer's Personal Data as long as required

to provide the Services to Customer under the Agreement;
for Company's legitimate business needs; or
by applicable law or regulation. Company Account Data and Company Usage Data will be processed and stored as set forth in Company's privacy policy.

3Categories of Data Subjects

Customer's employees, consultants, contractors, and/or agents.

4Categories 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.

Includes:

Name, email, job title, username
Company device identifiers (e.g. serial number)
IP address for company device
Installed applications for company device
Background check verification records (at discretion of Controller)
Security training records

5Sensitive Data or Special Categories of Data

Prohibited Data:

Customers are prohibited from providing sensitive personal data or special categories of data to Company, including without limitation, any data which discloses the criminal history.

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.

The Parties

Data exporter(s):

Name: Customer, as stated and defined in the applicable Order

Trading Name (if different):

Address: Customer's registered business address and any address provided to Linear

Official Registration Number:

Contact details: Customer's contact for the purposes of the SCC's will be the contact of the person that properly accepts and binds Customer to the Agreement

Activities: As described in Section 2 of the DPA

Signature and date: The UK SCC's and EU SCC's will be considered executed upon Customer's proper acceptance of the Agreement

Role: Controller

Data importer(s):

Name: Chatzuri.co, Inc.

Address: 4700 Keele Street, 215 Bergeron Centre, Toronto, ON, Canada, M3J 1P3

Contact: hello@chatzuri.com

Activities: As described in Section 2 of the DPA

Signature and date:

Role: As described in Section 2 of the DPA

Description of the Transfer

Field	Description
Data Subjects	As described in Exhibit A of the DPA
Categories of Personal Data	As described in Exhibit A of the DPA
Special Category Personal Data	As described in Exhibit A of the DPA
Nature of the Processing	As described in Exhibit A of the DPA
Purposes of Processing	As described in Exhibit A of the DPA
Duration of Processing and Retention	As described in Exhibit A of the DPA
Frequency of the transfer	As necessary to perform all obligations and rights with respect to Personal Data
Recipients of Personal Data	Company will maintain a list of Authorized Sub-Processors

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.

Exhibit C

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

The following includes the information required by Annex II of the EU SCCs and Annex II of the UK Addendum.

Technical and Organizational Security Measure	Details
Measures of pseudonymisation and encryption of personal data	Company has deployed secure methods and protocols for transmission of confidential or sensitive information over public networks. Databases housing sensitive customer data are encrypted at rest. Company uses only recommended secure cipher suites and protocols to encrypt all traffic in transit and Customer Data is securely encrypted with strong ciphers and configurations when at rest.
Measures for ensuring ongoing confidentiality, integrity, availability and resilience of processing systems and services	Company's customer agreements contain strict confidentiality obligations. Additionally, Company requires every downstream Subprocessor to sign confidentiality provisions that are substantially similar to those contained in Company's customer agreements.
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	Daily, weekly and monthly backups of production datastores are taken. Backups are periodically tested in accordance with information security and data management policies.
Measures for user identification and authorization	Company uses secure access protocols and processes and follows industry best-practices for authentication, including Multifactor Authentication and Single Sign On (SSO). All production access requires the use of two-factor authentication, and network infrastructure is securely configured to vendor and industry best practices to block all unnecessary ports, services, and unauthorized network traffic.
Measures for the protection of data during transmission	Company has deployed secure methods and protocols for transmission of confidential or sensitive information over public networks. Company uses only recommended secure cipher suites and protocols to encrypt all traffic in transit (i.e. TLS 1.2)
Measures for the protection of data during storage	Encryption-at-rest is automated using AWS's transparent disk encryption, which uses industry standard AES-256 encryption to secure all volume (disk) data. All keys are fully managed by AWS.
Measures for ensuring physical security of locations at which personal data are processed	All Company processing occurs in physical data centers that are managed by AWS. https://aws.amazon.com/compliance/data-center/controls/
Measures for ensuring events logging	Company monitors access to applications, tools, and resources that process or store Customer Data, including cloud services. Monitoring of security logs is managed by the security and engineering teams. Log activities are investigated when necessary and escalated appropriately.
Measures for ensuring system configuration, including default configuration	Company adheres to a change management process to administer changes to the production environment for the Services, including changes to its underlying software, applications, and systems. All production changes are automated through CI/CD tools to ensure consistent configurations.
Measures for ensuring data minimisation	Company's Customers unilaterally determine what data they route through the Services. As such, Company operates on a shared responsibility model. Company gives Customers control over exactly what data enters the platform. Additionally, Company has built in self-service functionality to the Services that allows Customers to delete and suppress data at their discretion.
Measures for ensuring data quality	Company has a multi-tiered approach for ensuring data quality. These measures include: (i) unit testing to ensure quality of logic used to process API calls, (ii) database schema validation rules which execute against data before it is saved to our database, (iii) a schema-first API design and strong typing to enforce a strict contract between official clients and API resolvers. Company applies these measures across the board, both to ensure the quality of any Usage Data that Company collects and to ensure that the Company Platform is operating within expected parameters. Company ensures that data quality is maintained from the time a Customer sends Customer Data into the Services and until that Customer Data is presented or exported.
Measures for ensuring limited data retention	Customers unilaterally determine what data they route through the Services. As such, Company operates on a shared responsibility model. If a Customer is unable to delete Personal Data via the self-services functionality of the Services, then the Company deletes such Personal Data upon the Customer's written request, within the timeframe specified in this DPA and in accordance with Applicable Data Protection Law. All Personal Data is deleted from the Services following service termination.
Measures for ensuring accountability	Company has adopted measures for ensuring accountability, such as implementing data protection and information security policies across the business, recording and reporting Personal Data Breaches, and formally assigning roles and responsibilities for information security and data privacy functions. Additionally, the Company conducts regular third-party audits to ensure compliance with our privacy and security standards.
Measures for allowing data portability and ensuring erasure	Personal Data submitted to the Services by Customer may be deleted by the Customer or at the Customer's request. Personal Data is incidental to the Company's Services. Based on Privacy by Design and Data Minimization principles, Company severely limits the instances of Personal Data collection and processing within the Services. Most use cases for porting Personal Data from Company are not applicable. However, Company will respond to all requests for data porting in order to address Customer needs.
Technical and organizational measures of sub-processors	The Company enters into Data Processing Agreements with its Authorized Sub-Processors with data protection obligations substantially similar to those contained in this DPA.

Exhibit D

UK Addendum

International Data Transfer Addendum to the EU Commission Standard Contractual Clauses

1Part 1: Tables

Table 1: Parties

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

Table 2: Selected SCCs, Modules and Selected Clauses

Field	Details
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 6.2 and 6.3 of the DPA.

Table 3: Appendix Information

"Appendix Information" means the information which must be provided for the selected modules as set out in the Appendix of the Approved EU SCCs (other than the Parties), and which for this UK Addendum is set out in:

Appendix	Reference
Annex 1A: List of Parties	As per Table 1 above
Annex 2B: 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

Note: This provision permits the selected party (if any) to terminate the UK Addendum if the ICO changes the approved UK Addendum which directly results in a substantial, disproportionate, and demonstrable increase in (a) its direct costs of performing its obligations under the UK Addendum or (b) its risk under the UK Addendum.

Ending this UK Addendum when the Approved UK Addendum changes	Selection
	✓Importer ✓Exporter ☐Neither Party

1Entering into this UK Addendum

Each party agrees to be bound by the terms and conditions set out in this UK Addendum, in exchange for the other party also agreeing to be bound by this UK Addendum.
Although Annex 1A and Clause 7 of the Approved EU SCCs require signature by the Parties, for the purpose of making ex-UK Transfers, the Parties may enter into this UK Addendum in any way that makes them legally binding on the Parties and allows data subjects to enforce their rights as set out in this UK Addendum. Entering into this UK Addendum will have the same effect as signing the Approved EU SCCs and any part of the Approved EU SCCs.

2Interpretation of this UK Addendum

Where this UK Addendum uses terms that are defined in the Approved EU SCCs those terms shall have the same meaning as in the Approved EU SCCs. In addition, the following terms have the following meanings:

Term	Definition
UK Addendum	means this International Data Transfer Addendum incorporating the EU SCCs, attached to the DPA as Exhibit D.
EU SCCs	means the version(s) of the Approved EU SCCs which this UK Addendum is appended to, as set out in Table 2, including the Appendix Information
Appendix Information	shall be as set out in Table 3
Appropriate Safeguards	means the standard of protection over the personal data and of data subjects' rights, which is required by UK Data Protection Laws when you are making an ex-UK Transfer relying on standard data protection clauses under Article 46(2)(d) UK GDPR.
Approved UK Addendum	means the template Addendum issued by the ICO and laid before Parliament in accordance with s119A of the Data Protection Act 2018 on 2 February 2022, as may be revised under Section 18 of the UK Addendum.
Approved EU SCCs	means the 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).
ICO	means the Information Commissioner of the United Kingdom.
ex-UK Transfer	shall have the same definition as set forth in the DPA.
UK	means the United Kingdom of Great Britain and Northern Ireland
UK Data Protection Laws	means all laws relating to data protection, the processing of personal data, privacy and/or electronic communications in force from time to time in the UK, including the UK GDPR and the Data Protection Act 2018.
UK GDPR	shall have the definition set forth in the DPA.

The UK Addendum must always be interpreted in a manner that is consistent with UK Data Protection Laws and so that it fulfills the Parties' obligation to provide the Appropriate Safeguards.
If the provisions included in the UK Addendum amend the Approved EU SCCs in any way which is not permitted under the Approved EU SCCs or the Approved UK Addendum, such amendment(s) will not be incorporated in the UK Addendum and the equivalent provision of the Approved EU SCCs will take their place.
If there is any inconsistency or conflict between UK Data Protection Laws and the UK Addendum, UK Data Protection Laws will apply.
If the meaning of the UK Addendum is unclear or there is more than one meaning, the meaning which most closely aligns with UK Data Protection Laws applies.
Any references to legislation (or specific provisions of legislation) means that legislation (or specific provision) as it may change over time. This includes where that legislation (or specific provision) has been consolidated, re-enacted and/or replaced after the UK Addendum has been entered into.

3Hierarchy

Although Clause 5 of the Approved EU SCCs sets out that the Approved EU SCCs prevail over all related agreements between the parties, the parties agree that, for ex-UK Transfers, the hierarchy in Section 10 below will prevail.
Where there is any inconsistency or conflict between the Approved UK Addendum and the EU SCCs (as applicable), the Approved UK Addendum overrides the EU SCCs, except where (and in so far as) the inconsistent or conflicting terms of the EU SCCs provides greater protection for data subjects, in which case those terms will override the Approved UK Addendum.
Where this UK Addendum incorporates EU SCCs which have been entered into to protect ex-EU Transfers subject to the GDPR, then the parties acknowledge that nothing in the UK Addendum impacts those EU SCCs.

4Incorporation and Changes to the EU SCCs

This UK Addendum incorporates the EU SCCs which are amended to the extent necessary so that:
1. together they operate for data transfers made by the data exporter to the data importer, to the extent that UK Data Protection Laws apply to the data exporter's processing when making that data transfer, and they provide Appropriate Safeguards for those data transfers;
2. Sections 9 to 11 above override Clause 5 (Hierarchy) of the EU SCCs; and
3. 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.
Unless the parties have agreed alternative amendments which meet the requirements of Section 12 of this UK Addendum, the provisions of Section 15 of this UK Addendum will apply.
No amendments to the Approved EU SCCs other than to meet the requirements of Section 12 of this UK Addendum may be made.
The following amendments to the EU SCCs (for the purpose of Section 12 of this UK Addendum) are made:
1. References to the "Clauses" means this UK Addendum, incorporating the EU SCCs;
2. In Clause 2, delete the words: "and, with respect to data transfers from controllers to processors and/or processors to processors, standard contractual clauses pursuant to Article 28(7) of Regulation (EU) 2016/679",
3. Clause 6 (Description of the transfer(s) is replaced with: "The details of the transfers(s) and in particular the categories of personal data that are transferred and the purpose(s) for which they are transferred) are those specified in Annex I.B where UK Data Protection Laws apply to the data exporter's processing when making that transfer.";
4. Clause 8.7(i) of Module 1 is replaced with: "it is to a country benefitting from adequacy regulations pursuant to Section 17A of the UK GDPR that covers the onward transfer";
5. Clause 8.8(i) of Modules 2 and 3 is replaced with: "the onward transfer is to a country benefitting from adequacy regulations pursuant to Section 17A of the UK GDPR that covers the onward transfer;"
6. References to "Regulation (EU) 2016/679", "Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation)" and "that Regulation" are all replaced by "UK Data Protection Laws". References to specific Article(s) of "Regulation (EU) 2016/679" are replaced with the equivalent Article or Section of UK Data Protection Laws;
7. References to Regulation (EU) 2018/1725 are removed;
8. References to the "European Union", "Union", "EU", "EU Member State", "Member State" and "EU or Member State" are all replaced with the "UK";
9. The reference to "Clause 12(c)(i)" at Clause 10(b)(i) of Module one, is replaced with "Clause 11(c)(i)";
10. Clause 13(a) and Part C of Annex I are not used;
11. The "competent supervisory authority" and "supervisory authority" are both replaced with the "Information Commissioner";
12. In Clause 16(e), subsection (i) is replaced with: "the Secretary of State makes regulations pursuant to Section 17A of the Data Protection Act 2018 that cover the transfer of personal data to which these clauses apply;";
13. Clause 17 is replaced with: &quote;These Clauses are governed by the laws of England and Wales&quote;;
14. Clause 18 is replaced with: &quote;Any dispute arising from these Clauses shall be resolved by the courts of England and Wales. &quote; A data subject may also bring legal proceedings against the data exporter and/or data importer before the courts of any country in the UK. The parties agree to submit themselves to the jurisdiction of such courts. &quote;; and
15. The footnotes to the Approved EU SCCs do not form part of the UK Addendum, except for footnotes 8, 9, 10 and 11.

5Amendments to the UK Addendum

The parties may agree to change Clauses 17 and/or 18 of the EU SCCs to refer to the laws and/or courts of Scotland or Northern Ireland.
If the parties wish to change the format of the information included in Part 1: Tables of the Approved UK Addendum, they may do so by agreeing to the change in writing, provided that the change does not reduce the Appropriate Safeguards.
From time to time, the ICO may issue a revised Approved UK Addendum which:
1. makes reasonable and proportionate changes to the Approved UK Addendum, including correcting errors in the Approved UK Addendum; and/or
2. reflects changes to UK Data Protection Laws;
The revised Approved UK Addendum will specify the start date from which the changes to the Approved UK Addendum are effective and whether the parties need to review this UK Addendum including the Appendix Information. This UK Addendum is automatically amended as set out in the revised Approved UK Addendum from the start date specified.
If the ICO issues a revised Approved UK Addendum under Section 18 of this UK Addendum, if a party will as a direct result of the changes in the Approved UK Addendum have a substantial, disproportionate and demonstrable increase in:
1. its direct costs of performing its obligations under the UK Addendum; and/or
2. its risk under the UK Addendum,
and in either case it has first taken reasonable steps to reduce those costs or risks so that it is not substantial and disproportionate, then that party may end this UK Addendum at the end of a reasonable notice period, by providing written notice for that period to the other party before the start date of the revised Approved UK Addendum.
The parties do not need the consent of any third party to make changes to this UK Addendum, but any changes must be made in accordance with its terms.

Data Processing Addendum

This DPA incorporates the terms of the Agreement, and any terms not defined in this DPA shall have the meaning set forth in the Agreement.

Definitions
1. "Affiliate" means:
  1. iAn entity of which a party directly or indirectly owns fifty percent (50%) or more of the stock or other equity interest
  2. iiAn entity that owns at least fifty percent (50%) or more of the stock or other equity interest of a party
  3. iiiAn entity which is under common control with a party by having at least fifty percent (50%) or more of the stock or other equity interest of such entity and a party owned by the same person, but such entity shall only be deemed to be an Affiliate so long as such ownership exists.
2. "Authorized Sub-Processor" means a third-party who has a need to know or otherwise access Customer's Personal Data to enable Company to perform its obligations under this DPA or the Agreement, and who is either:
  1. ilisted in Exhibit B or
  2. isubsequently authorized under Section 4.2 of this DPA.
3. "Customer Data" means any 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. Company Account Data also includes any data Company may need to collect for the purpose of managing its relationship with Customer, identity verification, or as otherwise required by applicable laws and regulations.
4. "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 data used to optimize and maintain performance of the Services, and to investigate and prevent system abuse.
5. "Data Exporter" means Customer.
6. "Data Importer" means Company.
7. "Data Protection Laws" means any applicable laws and regulations in any relevant jurisdiction relating to the use or processing of Personal Data including:
  1. ithe California Consumer Privacy Act ("CCPA")
  2. ii 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")
  3. iii the Swiss Federal Act on Data Protection
  4. ivthe UK Data Protection Act 2018
  5. vthe Privacy and Electronic Communications (EC Directive) Regulations 2003
  in each case, as updated, amended or replaced from time to time. The terms "Data Subject", "Personal Data", "Personal Data Breach", "processing", "processor," "controller," and "supervisory authority" shall have the meanings set forth in the GDPR.
8. "EU SCCs" means the 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 6.2 of this DPA.
9. "ex-EEA Transfer" means the transfer of Personal Data, which is processed in accordance with the GDPR, from the Data Exporter to the Data Importer (or its premises) outside the European Economic Area (the "EEA"), and such transfer is not governed by an adequacy decision made by the European Commission in accordance with the relevant provisions of the GDPR.
10. "ex-UK Transfer" means the transfer of Personal Data covered by Chapter V of the UK GDPR, which is processed in accordance with the UK GDPR and the Data Protection Act 2018, from the Data Exporter to the Data Importer (or its premises) outside the United Kingdom (the "UK"), and 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.
11. "Services" shall have the meaning set forth in the Agreement.
12. "Standard Contractual Clauses" means the EU SCCs and the UK SCCs.
13. "UK SCCs" means the EU SCCs, as amended by the UK Addendum.
Relationship of the Parties; Processing of Data
1. The parties acknowledge and agree that with regard to the processing of Personal Data, Customer may act either as a controller or processor and, except as expressly set forth in this DPA or the Agreement, Company is a processor. 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 Data Protection 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 Data Protection Laws. Customer is solely responsible for the accuracy, quality, and legality of:
  1. ithe Personal Data provided to Company by or on behalf of Customer
  2. iithe means by which Customer acquired any such Personal Data
  3. iiithe 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.
2. Company shall not process Personal Data:
  1. ifor purposes other than those set forth in the Agreement and/or Exhibit A
  2. iiin a manner inconsistent with the terms and conditions set forth in this DPA or any other documented instructions provided by Customer, including with regard to transfers of personal data to a third country or an international organization, unless required to do so by Supervisory Authority to which the Company is subject; in such a case, the Company shall inform the Customer of that legal requirement before processing, unless that law prohibits such information on important grounds of public interest
  3. iiiin violation of Data Protection Laws.
  Customer hereby instructs Company to process Personal Data in accordance with the foregoing and as part of any processing initiated by Customer in its use of the Services.
3. The subject matter, nature, purpose, and duration of this processing, as well as the types of Personal Data collected and categories of Data Subjects, are described in Exhibit A to this DPA.
4. Following completion of the Services, at Customer's choice, Company shall return or delete Customer's 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 6 (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.
5. CCPA. Except with respect to Company Account Data and Company Usage Data, the parties acknowledge and agree that Company is a service provider for the purposes of the CCPA (to the extent it applies) and is receiving personal information from Customer in order to provide the Services pursuant to the Agreement, which constitutes a business purpose. Company shall not sell any such personal information. Company shall not retain, use or disclose any personal information provided by Customer pursuant to the Agreement except as necessary for the specific purpose of performing the Services for Customer pursuant to the Agreement, or otherwise as set forth in the Agreement or as permitted by the CCPA. The terms "personal information," "service provider," "sale," and "sell" are as defined in Section 1798.140 of the CCPA. Company certifies that it understands the restrictions of this Section 2.5
Confidentiality
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.
Authorized Sub-Processors
1. Customer acknowledges and agrees that Company may
  1. iengage its Affiliates as well as the Authorized Sub-Processors on the List (defined below) to access and process Personal Data in connection with the Services and
  2. iifrom time to time engage additional third parties for the purpose of providing the Services, including without limitation the processing of Personal Data.
  By way of this DPA, Customer provides general written authorization to Company to engage sub-processors as necessary to perform the Services.
2. Company will provide a mechanism to subscribe to notifications (which may include but are not limited to email notifications) of new Authorized Sub-Processors and Customer, if it wishes, will subscribe to such notifications where available. If Customer does not subscribe to such notifications, Customer waives any right it may have to receive prior notice of changes to Authorized Sub-Processors. At least ten (10) days before enabling any third party other than existing Authorized Sub-Processors to access or participate in the processing of Personal Data, Company will add such third party to the List and notify subscribers, including Customer, via the aforementioned notifications. Customer may object to such an engagement by informing Company in writing within ten (10) days of receipt of the aforementioned notice by Customer, provided such objection is in writing and based on reasonable grounds relating to data protection. Customer acknowledges that certain sub-processors are essential to providing the Services and that objecting to the use of a sub-processor may prevent Company from offering the Services to Customer
3. If Customer reasonably objects to an engagement in accordance with Section 4.2, and Company cannot provide a commercially reasonable alternative within a reasonable period of time, Customer may discontinue the use of the affected Service by providing written notice to Company. Discontinuation shall not relieve Customer of any fees owed to Company under the Agreement.
4. If Customer does not object to the engagement of a third party in accordance with Section 4.2 within ten (10) days of notice by Company, that third party will be deemed an Authorized Sub-Processor for the purposes of this DPA.
5. Company will enter into a written agreement with the Authorized Sub-Processor imposing on the Authorized Sub-Processor data protection obligations comparable to those imposed on Company under this DPA with respect to the protection of Personal Data. In case an Authorized Sub-Processor 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 Sub-Processor's obligations under such agreement.
6. If Customer and Company have entered into Standard Contractual Clauses as described in Section 6 (Transfers of Personal Data),
  1. ithe above authorizations will constitute Customer's prior written consent to the subcontracting by Company of the processing of Personal Data if such consent is required under the Standard Contractual Clauses, and
  2. iithe parties agree that the copies of the agreements with Authorized Sub-Processors that must be provided by Company to Customer pursuant to Clause 9(c) of the EU SCCs may have commercial information, or information unrelated to the Standard Contractual Clauses or their equivalent, removed by the Company beforehand, and that such copies will be provided by the Company only upon request by Customer.
Security of Personal Data
1. 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.Exhibit C sets forth additional information about Company's technical and organizational security measures.
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 Customer's 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 Data Protection Laws
2. Ex-EEA Transfers. The parties agree that ex-EEA Transfers are made pursuant to the EU SCCs, which are deemed entered into (and incorporated into this DPA by this reference) and completed as follows:
  1. iModule One (Controller to Controller) of the EU SCCs apply when Company is processing Personal Data as a controller pursuant to Section 9 of this DPA.
  2. iModule Two (Controller to Processor) of the EU SCCs apply when Customer is a controller and Company is processing Personal Data for Customer as a processor pursuant to Section 2 of this DPA.
  3. iModule Three (Processor to Sub-Processor) of the EU SCCs apply when Customer is a processor and Company is processing Personal Data on behalf of Customer as a sub-processor.
3. For each module, where applicable the following applies:
  1. iThe optional docking clause in Clause 7 does not apply.
  2. iiIn Clause 9, Option 2 (general written authorization) applies, and the minimum time period for prior notice of sub-processor changes shall be as set forth in Section 4.2 of this DPA;
  3. iiiIn Clause 11, the optional language does not apply;
  4. ivAll square brackets in Clause 13 are hereby removed;
  5. vIn Clause 17 (Option 1), the EU SCCs will be governed by Ireland law.
  6. viIn Clause 18(b), disputes will be resolved before the courts of Ireland;
  7. viiExhibit B to this DPA contains the information required in Annex I and Annex III of the EU SCCs;
  8. viiiExhibit C to this DPA contains the information required in Annex II of the EU SCCs; and
  9. ixBy 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 are made pursuant to the UK SCCs, which are deemed entered into and incorporated into this DPA by reference, and amended and completed in accordance with the UK Addendum, which is incorporated herein as Exhibit D of this DPA
5. Transfers from Switzerland. The parties agree that transfers from Switzerland are made pursuant to the EU SCCs with the following modifications:
  1. iThe 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. iiThe terms of the EU SCCs shall be interpreted to protect the data of legal entities until the effective date of the Revised FADP.
  3. iiiClause 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 Section 13 shall be observed.
  4. iiiThe 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. Government Agency Requests and Data Transfer Safeguards:
  1. 1Current Status: As of the effective date of this DPA, the Data Importer confirms it has not received any formal legal requests from government intelligence or security agencies in the destination country for access to Customer's Personal Data ("Government Agency Requests" ).
  2. 2
    Request Handling Protocol: Should Government Agency Requests be received post-DPA execution:
    The Data Importer will attempt to redirect authorities to request data directly from Customer
    May provide Customer's basic contact information to facilitate direct communication
    If legally compelled to disclose, will provide Customer with reasonable notice (unless prohibited by law) and cooperate in seeking protective measures
    No voluntary disclosures will be made to government agencies
  3. 3
    Transfer Assessment: Both parties will promptly convene to evaluate:
    Whether the destination country's laws provide essentially equivalent protection to EEA/UK standards
    Necessity of supplemental safeguards for compliance with Data Protection Laws
    Continued appropriateness of transfers considering all relevant circumstances and regulatory guidance
  4. 4
    Legal Framework Adaptation: Where Data Protection Laws require:
    The Data Importer will promptly execute Standard Contractual Clauses (SCCs) with modifications reflecting transfer specifics and legal requirements
    If existing transfer mechanisms become invalid or are suspended by authorities, the Data Importer may implement alternative compliant arrangements with notice
Rights of Data Subjects
1. Data Subject Request Handling:
  1. 1
    Notification Obligation: Company shall, to the extent permitted by law, notify Customer upon receipt of a Data Subject Request to exercise rights of:
    Access
    Rectification
    Erasure ("right to be forgotten")
    Data portability
    Restriction or cessation of processing
    Withdrawal of consent
    Objection to automated decision-making
  2. 2
    Request Redirection: When Company receives a Data Subject Request regarding Customer's data:
    Company will instruct the Data Subject to submit their request directly to Customer
    Customer bears sole responsibility for responding to such requests
    Customer must use Service functionality where applicable
  3. 3
    Customer Responsibilities: Customer must:
    Ensure erasure, restriction, or consent withdrawal requests are properly communicated to Company
    Maintain records of consent where applicable
    Cover all reasonable costs for Company's assistance (where legally permitted)
  4. 4
    Limited Assistance: Company will provide technical and organizational assistance to help Customer comply with Data Subject Requests when:
    Customer cannot respond without Company's support
    Company can legally provide such assistance
    The nature of processing makes assistance feasible
    Note: All assistance is subject to applicable laws, rules, and regulations.
Actions and Access Requests; Audits
1. Compliance Assistance & Audit Rights:
  1. 1
    DPIA Assistance: Company shall provide reasonable cooperation to assist Customer with:
    Data Protection Impact Assessments (DPIAs) under GDPR
    Demonstrating compliance with GDPR obligations
    Limited to situations where Customer lacks access to relevant information
    Customer bears reasonable costs of such assistance
  2. 2
    Regulatory Cooperation: Company shall assist Customer with:
    Supervisory Authority consultations
    Regulatory cooperation required by GDPR
    Subject to nature of processing and information availability
  3. 3
    Record Keeping:
    Company maintains compliance records for 3 years post-termination
    Customer may review/audit records during business hours with notice
  4. 4
    Audit Rights:
    Upon request, Company provides:
    Compliance certifications/reports or
    Third-party audit access if reports are insufficient
    Audit conditions:
    Annual limit (1 audit/calendar year)
    Reasonable notice & business hours only
    Limited to Customer-relevant data
    Minimal business disruption
    Customer bears all audit costs
    For SCCs under Section 6, audits follow Clause 8.9 of EU SCCs
  5. 5
    Legal Compliance Notice: Company will notify Customer if instructions appear to violate:
    Data Protection Laws
    Supervisory Authority requirements
  6. 6
    Breach Notification:
    Company shall:
    Notify Customer without undue delay
    Take reasonable remediation steps
    Exclusions:
    Breaches caused by Customer actions/omissions
    Notification doesn't constitute fault admission
  7. 7
    Breach Cooperation: Company shall assist Customer with:
    Supervisory Authority notifications
    Data Subject communications
    GDPR compliance obligations
    Considering nature of processing and available information
Company's Role as a Controller.
1. Controller Responsibilities:
  1. 1
    Controller Status: The parties acknowledge that:
    For Company Account Data and Company Usage Data, Company acts as an independent controller
    No joint controller relationship exists for these data types
  2. 2
    Processing Purposes: As controller, Company processes data for:
    Managing the customer relationship
    Core business operations:
    Accounting & audits
    Tax preparation & filing
    Compliance purposes
    Security monitoring:
    Fraud prevention/detection
    Security incident investigation
    Service misuse prevention
    Identity verification
    Legal/regulatory compliance
    Other lawful purposes under Data Protection Laws
  3. 3
    Service Optimization: Company may process Usage Data to:
    Provide, maintain, and improve Services
    Optimize service performance
    When permitted by Data Protection Laws
  4. 4
    Privacy Policy: All controller processing is governed by:
    Company's Privacy Policy available at: https://www.chatzuri.com/privacy-policy
    Terms of this DPA
    The main Agreement
Conflict
1. In the event of any conflict or inconsistency among the following documents, the order of precedence will be:
  1. ithe applicable terms in the Standard Contractual Clauses;
  2. iithe terms of this DPA;
  3. iithe Agreement; and
  4. iithe Company's privacy policy. and
  Any claims brought in connection with this DPA will be subject to the terms and conditions, including, but not limited to, the exclusions and limitations set forth in the Agreement.

Exhibit A

Details of Processing

1Nature and Purpose of Processing

Receiving data, including collection, accessing, retrieval, recording, and data entry
Protecting data, including restricting, encrypting, and security testing
Holding data, including storage, organization, and structuring
Erasing data, including destruction and deletion
Analyzing data, including product usage assessment
Sharing data, including disclosure to subprocessors as permitted in this DPA

2Duration of Processing

Company will process Customer's Personal Data as long as required

to provide the Services to Customer under the Agreement;
for Company's legitimate business needs; or
by applicable law or regulation. Company Account Data and Company Usage Data will be processed and stored as set forth in Company's privacy policy.

3Categories of Data Subjects

Customer's employees, consultants, contractors, and/or agents.

4Categories of Personal Data

Includes:

Name, email, job title, username
Company device identifiers (e.g. serial number)
IP address for company device
Installed applications for company device
Background check verification records (at discretion of Controller)
Security training records

5Sensitive Data or Special Categories of Data

Prohibited Data:

Customers are prohibited from providing sensitive personal data or special categories of data to Company, including without limitation, any data which discloses the criminal history.

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.

The Parties

Data exporter(s):

Name: Customer, as stated and defined in the applicable Order

Trading Name (if different):

Address: Customer's registered business address and any address provided to Linear

Official Registration Number:

Contact details: Customer's contact for the purposes of the SCC's will be the contact of the person that properly accepts and binds Customer to the Agreement

Activities: As described in Section 2 of the DPA

Signature and date: The UK SCC's and EU SCC's will be considered executed upon Customer's proper acceptance of the Agreement

Role: Controller

Data importer(s):

Name: Chatzuri.co, Inc.

Address: 4700 Keele Street, 215 Bergeron Centre, Toronto, ON, Canada, M3J 1P3

Contact: hello@chatzuri.com

Activities: As described in Section 2 of the DPA

Signature and date:

Role: As described in Section 2 of the DPA

Description of the Transfer

Field	Description
Data Subjects	As described in Exhibit A of the DPA
Categories of Personal Data	As described in Exhibit A of the DPA
Special Category Personal Data	As described in Exhibit A of the DPA
Nature of the Processing	As described in Exhibit A of the DPA
Purposes of Processing	As described in Exhibit A of the DPA
Duration of Processing and Retention	As described in Exhibit A of the DPA
Frequency of the transfer	As necessary to perform all obligations and rights with respect to Personal Data
Recipients of Personal Data	Company will maintain a list of Authorized Sub-Processors

Competent Supervisory Authority

Exhibit C

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

The following includes the information required by Annex II of the EU SCCs and Annex II of the UK Addendum.

Technical and Organizational Security Measure	Details
Measures of pseudonymisation and encryption of personal data	Company has deployed secure methods and protocols for transmission of confidential or sensitive information over public networks. Databases housing sensitive customer data are encrypted at rest. Company uses only recommended secure cipher suites and protocols to encrypt all traffic in transit and Customer Data is securely encrypted with strong ciphers and configurations when at rest.
Measures for ensuring ongoing confidentiality, integrity, availability and resilience of processing systems and services	Company's customer agreements contain strict confidentiality obligations. Additionally, Company requires every downstream Subprocessor to sign confidentiality provisions that are substantially similar to those contained in Company's customer agreements.
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	Daily, weekly and monthly backups of production datastores are taken. Backups are periodically tested in accordance with information security and data management policies.
Measures for user identification and authorization	Company uses secure access protocols and processes and follows industry best-practices for authentication, including Multifactor Authentication and Single Sign On (SSO). All production access requires the use of two-factor authentication, and network infrastructure is securely configured to vendor and industry best practices to block all unnecessary ports, services, and unauthorized network traffic.
Measures for the protection of data during transmission	Company has deployed secure methods and protocols for transmission of confidential or sensitive information over public networks. Company uses only recommended secure cipher suites and protocols to encrypt all traffic in transit (i.e. TLS 1.2)
Measures for the protection of data during storage	Encryption-at-rest is automated using AWS's transparent disk encryption, which uses industry standard AES-256 encryption to secure all volume (disk) data. All keys are fully managed by AWS.
Measures for ensuring physical security of locations at which personal data are processed	All Company processing occurs in physical data centers that are managed by AWS. https://aws.amazon.com/compliance/data-center/controls/
Measures for ensuring events logging	Company monitors access to applications, tools, and resources that process or store Customer Data, including cloud services. Monitoring of security logs is managed by the security and engineering teams. Log activities are investigated when necessary and escalated appropriately.
Measures for ensuring system configuration, including default configuration	Company adheres to a change management process to administer changes to the production environment for the Services, including changes to its underlying software, applications, and systems. All production changes are automated through CI/CD tools to ensure consistent configurations.
Measures for ensuring data minimisation	Company's Customers unilaterally determine what data they route through the Services. As such, Company operates on a shared responsibility model. Company gives Customers control over exactly what data enters the platform. Additionally, Company has built in self-service functionality to the Services that allows Customers to delete and suppress data at their discretion.
Measures for ensuring data quality	Company has a multi-tiered approach for ensuring data quality. These measures include: (i) unit testing to ensure quality of logic used to process API calls, (ii) database schema validation rules which execute against data before it is saved to our database, (iii) a schema-first API design and strong typing to enforce a strict contract between official clients and API resolvers. Company applies these measures across the board, both to ensure the quality of any Usage Data that Company collects and to ensure that the Company Platform is operating within expected parameters. Company ensures that data quality is maintained from the time a Customer sends Customer Data into the Services and until that Customer Data is presented or exported.
Measures for ensuring limited data retention	Customers unilaterally determine what data they route through the Services. As such, Company operates on a shared responsibility model. If a Customer is unable to delete Personal Data via the self-services functionality of the Services, then the Company deletes such Personal Data upon the Customer's written request, within the timeframe specified in this DPA and in accordance with Applicable Data Protection Law. All Personal Data is deleted from the Services following service termination.
Measures for ensuring accountability	Company has adopted measures for ensuring accountability, such as implementing data protection and information security policies across the business, recording and reporting Personal Data Breaches, and formally assigning roles and responsibilities for information security and data privacy functions. Additionally, the Company conducts regular third-party audits to ensure compliance with our privacy and security standards.
Measures for allowing data portability and ensuring erasure	Personal Data submitted to the Services by Customer may be deleted by the Customer or at the Customer's request. Personal Data is incidental to the Company's Services. Based on Privacy by Design and Data Minimization principles, Company severely limits the instances of Personal Data collection and processing within the Services. Most use cases for porting Personal Data from Company are not applicable. However, Company will respond to all requests for data porting in order to address Customer needs.
Technical and organizational measures of sub-processors	The Company enters into Data Processing Agreements with its Authorized Sub-Processors with data protection obligations substantially similar to those contained in this DPA.

Exhibit D

UK Addendum

International Data Transfer Addendum to the EU Commission Standard Contractual Clauses

1Part 1: Tables

Table 1: Parties

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

Table 2: Selected SCCs, Modules and Selected Clauses

Field	Details
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 6.2 and 6.3 of the DPA.

Table 3: Appendix Information

Appendix	Reference
Annex 1A: List of Parties	As per Table 1 above
Annex 2B: 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	Selection
	✓Importer ✓Exporter ☐Neither Party

1Entering into this UK Addendum

Each party agrees to be bound by the terms and conditions set out in this UK Addendum, in exchange for the other party also agreeing to be bound by this UK Addendum.
Although Annex 1A and Clause 7 of the Approved EU SCCs require signature by the Parties, for the purpose of making ex-UK Transfers, the Parties may enter into this UK Addendum in any way that makes them legally binding on the Parties and allows data subjects to enforce their rights as set out in this UK Addendum. Entering into this UK Addendum will have the same effect as signing the Approved EU SCCs and any part of the Approved EU SCCs.

2Interpretation of this UK Addendum

Term	Definition
UK Addendum	means this International Data Transfer Addendum incorporating the EU SCCs, attached to the DPA as Exhibit D.
EU SCCs	means the version(s) of the Approved EU SCCs which this UK Addendum is appended to, as set out in Table 2, including the Appendix Information
Appendix Information	shall be as set out in Table 3
Appropriate Safeguards	means the standard of protection over the personal data and of data subjects' rights, which is required by UK Data Protection Laws when you are making an ex-UK Transfer relying on standard data protection clauses under Article 46(2)(d) UK GDPR.
Approved UK Addendum	means the template Addendum issued by the ICO and laid before Parliament in accordance with s119A of the Data Protection Act 2018 on 2 February 2022, as may be revised under Section 18 of the UK Addendum.
Approved EU SCCs	means the 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).
ICO	means the Information Commissioner of the United Kingdom.
ex-UK Transfer	shall have the same definition as set forth in the DPA.
UK	means the United Kingdom of Great Britain and Northern Ireland
UK Data Protection Laws	means all laws relating to data protection, the processing of personal data, privacy and/or electronic communications in force from time to time in the UK, including the UK GDPR and the Data Protection Act 2018.
UK GDPR	shall have the definition set forth in the DPA.

The UK Addendum must always be interpreted in a manner that is consistent with UK Data Protection Laws and so that it fulfills the Parties' obligation to provide the Appropriate Safeguards.
If the provisions included in the UK Addendum amend the Approved EU SCCs in any way which is not permitted under the Approved EU SCCs or the Approved UK Addendum, such amendment(s) will not be incorporated in the UK Addendum and the equivalent provision of the Approved EU SCCs will take their place.
If there is any inconsistency or conflict between UK Data Protection Laws and the UK Addendum, UK Data Protection Laws will apply.
If the meaning of the UK Addendum is unclear or there is more than one meaning, the meaning which most closely aligns with UK Data Protection Laws applies.
Any references to legislation (or specific provisions of legislation) means that legislation (or specific provision) as it may change over time. This includes where that legislation (or specific provision) has been consolidated, re-enacted and/or replaced after the UK Addendum has been entered into.

3Hierarchy

Although Clause 5 of the Approved EU SCCs sets out that the Approved EU SCCs prevail over all related agreements between the parties, the parties agree that, for ex-UK Transfers, the hierarchy in Section 10 below will prevail.
Where there is any inconsistency or conflict between the Approved UK Addendum and the EU SCCs (as applicable), the Approved UK Addendum overrides the EU SCCs, except where (and in so far as) the inconsistent or conflicting terms of the EU SCCs provides greater protection for data subjects, in which case those terms will override the Approved UK Addendum.
Where this UK Addendum incorporates EU SCCs which have been entered into to protect ex-EU Transfers subject to the GDPR, then the parties acknowledge that nothing in the UK Addendum impacts those EU SCCs.

4Incorporation and Changes to the EU SCCs

This UK Addendum incorporates the EU SCCs which are amended to the extent necessary so that:
1. together they operate for data transfers made by the data exporter to the data importer, to the extent that UK Data Protection Laws apply to the data exporter's processing when making that data transfer, and they provide Appropriate Safeguards for those data transfers;
2. Sections 9 to 11 above override Clause 5 (Hierarchy) of the EU SCCs; and
3. 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.
Unless the parties have agreed alternative amendments which meet the requirements of Section 12 of this UK Addendum, the provisions of Section 15 of this UK Addendum will apply.
No amendments to the Approved EU SCCs other than to meet the requirements of Section 12 of this UK Addendum may be made.
The following amendments to the EU SCCs (for the purpose of Section 12 of this UK Addendum) are made:
1. References to the "Clauses" means this UK Addendum, incorporating the EU SCCs;
2. In Clause 2, delete the words: "and, with respect to data transfers from controllers to processors and/or processors to processors, standard contractual clauses pursuant to Article 28(7) of Regulation (EU) 2016/679",
3. Clause 6 (Description of the transfer(s) is replaced with: "The details of the transfers(s) and in particular the categories of personal data that are transferred and the purpose(s) for which they are transferred) are those specified in Annex I.B where UK Data Protection Laws apply to the data exporter's processing when making that transfer.";
4. Clause 8.7(i) of Module 1 is replaced with: "it is to a country benefitting from adequacy regulations pursuant to Section 17A of the UK GDPR that covers the onward transfer";
5. Clause 8.8(i) of Modules 2 and 3 is replaced with: "the onward transfer is to a country benefitting from adequacy regulations pursuant to Section 17A of the UK GDPR that covers the onward transfer;"
6. References to "Regulation (EU) 2016/679", "Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation)" and "that Regulation" are all replaced by "UK Data Protection Laws". References to specific Article(s) of "Regulation (EU) 2016/679" are replaced with the equivalent Article or Section of UK Data Protection Laws;
7. References to Regulation (EU) 2018/1725 are removed;
8. References to the "European Union", "Union", "EU", "EU Member State", "Member State" and "EU or Member State" are all replaced with the "UK";
9. The reference to "Clause 12(c)(i)" at Clause 10(b)(i) of Module one, is replaced with "Clause 11(c)(i)";
10. Clause 13(a) and Part C of Annex I are not used;
11. The "competent supervisory authority" and "supervisory authority" are both replaced with the "Information Commissioner";
12. In Clause 16(e), subsection (i) is replaced with: "the Secretary of State makes regulations pursuant to Section 17A of the Data Protection Act 2018 that cover the transfer of personal data to which these clauses apply;";
13. Clause 17 is replaced with: &quote;These Clauses are governed by the laws of England and Wales&quote;;
14. Clause 18 is replaced with: &quote;Any dispute arising from these Clauses shall be resolved by the courts of England and Wales. &quote; A data subject may also bring legal proceedings against the data exporter and/or data importer before the courts of any country in the UK. The parties agree to submit themselves to the jurisdiction of such courts. &quote;; and
15. The footnotes to the Approved EU SCCs do not form part of the UK Addendum, except for footnotes 8, 9, 10 and 11.

5Amendments to the UK Addendum

The parties may agree to change Clauses 17 and/or 18 of the EU SCCs to refer to the laws and/or courts of Scotland or Northern Ireland.
If the parties wish to change the format of the information included in Part 1: Tables of the Approved UK Addendum, they may do so by agreeing to the change in writing, provided that the change does not reduce the Appropriate Safeguards.
From time to time, the ICO may issue a revised Approved UK Addendum which:
1. makes reasonable and proportionate changes to the Approved UK Addendum, including correcting errors in the Approved UK Addendum; and/or
2. reflects changes to UK Data Protection Laws;
The revised Approved UK Addendum will specify the start date from which the changes to the Approved UK Addendum are effective and whether the parties need to review this UK Addendum including the Appendix Information. This UK Addendum is automatically amended as set out in the revised Approved UK Addendum from the start date specified.
If the ICO issues a revised Approved UK Addendum under Section 18 of this UK Addendum, if a party will as a direct result of the changes in the Approved UK Addendum have a substantial, disproportionate and demonstrable increase in:
1. its direct costs of performing its obligations under the UK Addendum; and/or
2. its risk under the UK Addendum,
and in either case it has first taken reasonable steps to reduce those costs or risks so that it is not substantial and disproportionate, then that party may end this UK Addendum at the end of a reasonable notice period, by providing written notice for that period to the other party before the start date of the revised Approved UK Addendum.
The parties do not need the consent of any third party to make changes to this UK Addendum, but any changes must be made in accordance with its terms.

Privacy Statement

Data Processing Addendum

Definitions

Relationship of the Parties; Processing of Data

Confidentiality

Authorized Sub-Processors

Security of Personal Data

Transfers of Personal Data

Rights of Data Subjects

Actions and Access Requests; Audits

Company's Role as a Controller.

Conflict

Exhibit A

Details of Processing

1Nature and Purpose of Processing

2Duration of Processing

3Categories of Data Subjects

4Categories of Personal Data

5Sensitive Data or Special Categories of Data

Exhibit B

The Parties

The Parties

Data exporter(s):

Data importer(s):

Description of the Transfer

Description of the Transfer

Competent Supervisory Authority

Competent Supervisory Authority

Exhibit C

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

Exhibit D

UK Addendum

International Data Transfer Addendum to the EU Commission Standard Contractual Clauses

1Part 1: Tables

Table 1: Parties

Table 2: Selected SCCs, Modules and Selected Clauses

Table 3: Appendix Information

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

1Entering into this UK Addendum

2Interpretation of this UK Addendum

3Hierarchy

4Incorporation and Changes to the EU SCCs

5Amendments to the UK Addendum

Privacy Statement

Data Processing Addendum

Definitions

Relationship of the Parties; Processing of Data

Confidentiality

Authorized Sub-Processors

Security of Personal Data

Transfers of Personal Data

Rights of Data Subjects

Actions and Access Requests; Audits

Company's Role as a Controller.

Conflict

Exhibit A

Details of Processing

1Nature and Purpose of Processing

2Duration of Processing

3Categories of Data Subjects

4Categories of Personal Data

5Sensitive Data or Special Categories of Data

Exhibit B

The Parties

The Parties

Data exporter(s):

Data importer(s):

Description of the Transfer

Description of the Transfer

Competent Supervisory Authority

Competent Supervisory Authority

Exhibit C

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

Exhibit D

UK Addendum

International Data Transfer Addendum to the EU Commission Standard Contractual Clauses

1Part 1: Tables

Table 1: Parties

Table 2: Selected SCCs, Modules and Selected Clauses

Table 3: Appendix Information