Data Processing Addendum

Revision Date: 03/28/2023

1. Introduction

This Data Processing Addendum (“Addendum”) is made and entered into by and between AccAlly (“Company”) and the data subjects (“Data Subjects”). This Addendum is effective as of the date of execution by both parties and is hereby incorporated into and shall be governed by the terms of the underlying agreement between the parties.

2. Scope of Processing

The Company shall process Data Subjects’ personal data and any other information provided by the Data Subjects in connection with the services provided by the Company in accordance with the terms of the agreement.

3. Data Protection Requirements

The Company shall process Data Subjects’ personal data in accordance with applicable laws and regulations governing data protection, including but not limited to the European Union General Data Protection Regulation (GDPR).

4. Data Subjects’ Rights

The Company shall respect the rights of Data Subjects as set out in the applicable data protection laws and regulations and shall take reasonable steps to facilitate the exercise of such rights.

5. Data Security and Confidentiality

The Company shall implement appropriate technical and organizational measures to protect the privacy and security of Data Subjects’ personal data. The Company shall maintain the confidentiality of Data Subjects’ personal data and shall not disclose it to unauthorized third parties.

6. Data Retention and Destruction

The Company shall retain Data Subjects’ personal data only for as long as is necessary to fulfill the purposes for which the data was collected and processed, and shall take reasonable steps to securely delete or destroy all such data when it is no longer required.

7. Data Transfer

The Company shall not transfer or otherwise make available Data Subjects’ personal data to any country or territory outside the European Economic Area, unless it has obtained prior written consent from all Data Subjects and has taken all necessary steps to ensure that the data is adequately protected.

8. Data Breach Notification

The Company shall notify Data Subjects without undue delay in the event of a personal data breach.

9. Contact Details

The Company shall provide Data Subjects with contact details so that they can exercise their rights under data protection laws.

10. Dispute Resolution:

The parties shall attempt to resolve any dispute related to this Addendum through negotiation and mediation.

11. Governing Law

This Addendum shall be governed by and interpreted in accordance with the laws of the country in which the Company is located.

12. Severability

If any provision of this Addendum is found to be invalid, illegal or unenforceable, the remainder of the Addendum shall remain in full force and effect.

13. No Waiver

No waiver of any provision of this Addendum shall be deemed to have been made unless it is in writing and signed by the parties.

14. Entire Agreement

This Addendum constitutes the entire agreement between the parties with respect to the subject matter hereof and supersedes any prior oral or written agreements or understandings between the parties.