Data Processing Agreement

This DPA is entered into between the Controller and the Processor and is incorporated into and governed by the terms of the Agreement.

1. Definitions

   Any capitalized term not defined in this DPA shall have the meaning given to it in the Agreement.

   • "Affiliate" means any entity that directly or INDIRECTLY controls, is controlled by, or is under common control of a party. "Control", for purposes of this definition, means direct or indirect ownership or control of more than 50% of the voting interests of a party;

   • "Agreement" means the agreement between the Controller and the Processor for the provision of the Services;

   • "CCPA" means the California Consumer Privacy Act of 2018, along with its regulations and as amended from time to time;

   • "Controller" means the Customer;

   • "Data Protection Law" means all laws and regulations, including laws and regulations of the European Union, the European Economic Area, their member states and the United Kingdom, any amendments, replacements or renewals thereof, applicable to the processing of Personal Data, including where applicable the Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2020, the EU GDPR, the UK GDPR, the UK Data Protection Act 2018, the FADP, the CCPA, the Singapore Personal Data Protection Act 2012 and the Personal Data Protection (Amendment) Act 2020 (together "PDPA") and any applicable national implementing laws, regulations and secondary legislation relating to the processing of the Personal Data and the privacy of electronic communications, as amended, replaced or updated from time to time, including the Privacy and Electronic Communications Directive (2002/58/EC) and the Privacy and Electronic Communications (EC Directive) Regulations 2003 (SI 2003/2426);

   • "Data Subject" shall have the same meaning as in Data Protection Law or means a "Consumer" as that term is defined in the CCPA;

   • "DPA" means this data processing agreement together with Exhibits A, B, C, D and E;

   • "EEA" means the European Economic Area;

   • "EU GDPR" means 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);

   • "FADP" means the new Swiss Federal Act on Data Protection of 1st of September 2023, and as amended from time to time;

   • "Personal Data" shall have the same meaning as in Data Protection Law;

   • "Processor" means the Company, including as applicable any "Service Provider" as that term is defined by the CCPA and any "Data Intermediary" as that term is defined by the PDPA;

   • "Restricted Transfer" means:

     • where the EU GDPR applies, a transfer of Personal Data via the Services from the EEA either directly or via onward transfer, to any country or recipient outside of the EEA not subject to an adequacy determination by the European Commission; and
     • where the UK GDPR applies, a transfer of Personal Data via the Services from the United Kingdom either directly or via onward transfer, to any country or recipient outside of the UK not based on adequacy regulations pursuant to Section 17A of the United Kingdom Data Protection Act 2018; and
     • a transfer of Personal Data via the Services from Switzerland either directly or via onward transfer, to any country or recipient outside of the EEA and/or Switzerland not subject to an adequacy determination by the European Commission;

   • "Services" means all services and software applications and solutions provided to the Controller by the Processor under and as described in the Agreement;

   • "SCCs" means:

     • where the EU GDPR applies, the standard contractual clauses annexed to the European Commission's Implementing Decision 2021/914 of 4 June 2021 on standard contractual clauses for the transfer of personal data to third countries published at https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32021D0914&from=EN, ("EU SCCs"); and
     • where the UK GDPR applies standard data protection clauses adopted pursuant to Article 46(2)(c) of the UK GDPR as set out in Exhibit C of this DPA, ("UK SCCs"); and
     • where Personal Data is transferred from Switzerland to outside of Switzerland or the EEA, the EU SCCs as amended in accordance with guidance from the Swiss Data Protection Authority; ("Swiss SCCs");

   • "Sub-processor" means any third party (including the Processor's Affiliates) engaged directly or indirectly by the Processor to process Personal Data under this DPA in the provision of the Services to the Controller;

   • "Supervisory Authority" means a governmental or government chartered regulatory body having binding legal authority over a party;

   • "UK GDPR" means the EU GDPR as it forms part of the law of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018.

2. Purpose

   1. The Processor has agreed to provide the Services to the Controller in accordance with the terms of the Agreement. In providing the Services, the Processor shall process Customer Data on behalf of the Controller. Customer Data may include Personal Data. The Processor will process and protect such Personal Data in accordance with the terms of this DPA.

3. Scope

   1. In providing the Services to the Controller pursuant to the terms of the Agreement, the Processor shall process Personal Data only to the extent necessary to provide the Services in accordance with the terms of the Agreement, this DPA and the Controller's instructions documented in the Agreement and this DPA, as updated from time to time.
   2. The Controller and Processor shall take steps to ensure that any natural person acting under the authority of the Controller or the Processor who has access to Personal Data does not process them except on the instructions from the Controller unless required to do so by any Data Protection Law.

4. Processor's Obligations

   1. The Processor may collect, process or use Personal Data only within the scope of this DPA.
   2. The Processor confirms that it shall process Personal Data on behalf of the Controller in accordance with the documented instructions of the Controller.
   3. The Processor shall promptly inform the Controller, if in the Processor's opinion, any of the instructions regarding the processing of Personal Data provided by the Controller, breach Data Protection Law.
   4. The Processor shall ensure that all employees, agents, officers and contractors involved in the handling of Personal Data: (i) are aware of the confidential nature of the Personal Data and are contractually bound to keep the Personal Data confidential; (ii) have received appropriate training on their responsibilities as a data processor; and (iii) are bound by the terms of this DPA.
   5. The Processor shall implement appropriate technical and organizational measures to protect Personal Data, 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.
   6. The Processor shall implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including inter alia as appropriate: (i) the pseudonymization and encryption of Personal Data; (ii) the ability to ensure the on-going confidentiality, integrity, availability and resilience of processing systems and services; (iii) the ability to restore the availability and access to Personal Data in a timely manner in the event of a physical or technical incident; (iv) a process for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing. In accessing the appropriate level of security, account shall be taken in particular of the risks that are presented by processing, in particular from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data transmitted, stored or otherwise processed.
   7. The technical and organizational measures detailed in Exhibit B shall at all times be adhered to as a minimum security standard. The Controller accepts and agrees that the technical and organizational measures are subject to development and review and that the Processor may use alternative suitable measures to those detailed in the attachments to this DPA, provided such measures are at least equivalent to the technical and organizational measures set out in Exhibit B and appropriate pursuant to the Processor's obligations in clauses 4.5 and 4.6 above.
   8. The Controller acknowledges and agrees that, in the course of providing the Services to the Controller, it may be necessary for the Processor to access the Personal Data to respond to any technical problems or Controller queries and to ensure the proper working of the Services. All such access by the Processor will be limited to those purposes.
   9. Taking into account the nature of the processing and the information available to the Processor, the Processor shall assist the Controller by having in place appropriate technical and organizational measures, insofar as this is possible, for the fulfillment of the Controller's obligation to respond to requests for exercising the Data Subject's rights and the Controller's compliance with the Controller's data protection obligations in respect of the processing of Personal Data.
   10. The Processor may not: (i) sell Personal Data; (ii) retain, use, or disclose Personal Data for commercial purposes other than providing the Services under the terms of the Agreement; (iii) retain, use, or disclose Personal Data outside of the terms of the Agreement; or (iv) use Personal Data to train, fine-tune or otherwise improve any artificial intelligence or machine-learning model used to provide services to any party other than the Controller.
   11. The Processor shall maintain records of processing activities carried out on behalf of the Controller as required under Article 30(2) of the EU GDPR and equivalent provisions under applicable Data Protection Law.

5. Controller's Obligations

   1. The Controller represents and warrants that: (i) it shall comply with this DPA and its obligations under Data Protection Law; (ii) it has obtained any, and all, necessary permissions and authorizations necessary to permit the Processor, its Affiliates and Sub-processors, to execute their rights or perform their obligations under this DPA; and (iii) all Affiliates of the Controller who use the Services shall comply with the obligations of the Controller set out in this DPA.
   2. The Controller shall implement appropriate technical and organizational measures to protect Personal Data, 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. The Controller shall implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including inter alia as appropriate: (i) the pseudonymization and encryption of Personal Data; (ii) the ability to ensure the on-going confidentiality, integrity, availability and resilience of processing systems and services; (iii) the ability to restore the availability and access to Personal Data in a timely manner in the event of a physical or technical incident; (iv) a process for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing. In accessing the appropriate level of security account shall be taken in particular of the risks that are presented by processing, in particular from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data transmitted, stored or otherwise processed.
   3. The Controller acknowledges and agrees that some instructions from the Controller including the Processor assisting with audits, inspections, DPIAs or providing any assistance under this DPA, may result in additional fees. In such case the Processor shall notify the Controller in advance and shall be entitled to charge the Controller for its reasonable costs and expenses in providing such assistance, up to the sum of 1 500 Singapore Dollars per day.

6. Sub-processors

   1. The Controller acknowledges and agrees that the Processor may engage Sub-processors in connection with the provision of the Services.
   2. All Sub-processors who process Personal Data in the provision of the Services to the Controller shall comply with the obligations of the Processor set out in this DPA.
   3. The Controller authorizes the Processor to use the Sub-processors included in the list of Sub-processors published at: https://parseur.com/dpa-subprocessors to process the Personal Data. During the term of this DPA, the Processor shall provide the Controller with 30 days prior notification, via email, of any changes to the list of Sub-processors before authorizing any new or replacement Sub-processor to process Personal Data in connection with provision of the Services.
   4. The Controller may object to the use of a new or replacement Sub-processor, by notifying the Processor promptly in writing within fifteen (15) days after receipt of the Processor's notice. If the Controller objects to a new or replacement Sub-processor, the Controller may terminate the Agreement with respect to those Services which cannot be provided by the Processor without the use of the new or replacement Sub-processor. The Processor will refund the Controller any prepaid fees covering the remainder of the term of the Agreement following the effective date of termination with respect to such terminated Services.
   5. All Sub-processors who process Personal Data shall comply with the obligations of the Processor set out in this DPA. The Processor shall prior to the relevant Sub-processor carrying out any processing activities in respect of the Personal Data: (i) appoint each Sub-processor under a written contract containing materially the same obligations to those of the Processor in this DPA enforceable by the Processor; and (ii) ensure each such Sub-processor complies with all such obligations.
   6. The Controller agrees that the Processor and its Sub-processors may make Restricted Transfers of Personal Data for the purpose of providing the Services to the Controller in accordance with the Agreement. The Processor confirms that such Sub-processors: (i) are located in a third country or territory recognized by the EU Commission or a Supervisory Authority, as applicable, to have an adequate level of protection; or (ii) have entered into the applicable SCCs with the Processor; or (iii) have other legally recognized appropriate safeguards in place.

7. Restricted Transfers

   1. The parties agree that, when a transfer of Personal Data occurs between the Controller and the Processor or from the Processor to a Sub-processor which is a Restricted Transfer, it shall be subject to the applicable SCCs.

   2. The parties agree that the EU SCCs shall apply to Restricted Transfers from the EEA. The EU SCCs shall be deemed entered into (and incorporated into this DPA by reference) and completed as follows:

      1. Module Two (Controller to Processor) shall apply where the Customer is a Controller of Personal Data and the Company is processing Personal Data;
      2. Module Three (Processor to Processor) shall apply where the Company is a Processor of Personal Data and the Company uses a Sub-processor to process the Personal Data;
      3. Module Four (Processor to Controller) shall apply where the Company is processing Personal Data and the Customer is not subject to the EU GDPR or UK GDPR;
      4. In Clause 7 of the EU SCCs, the optional docking clause shall not apply;
      5. In Clause 9 of the EU SCCs, Option 2 applies, and the time period for giving notice of Sub-processor changes shall be as set out in clause 6.3 of this DPA;
      6. In Clause 11 of the EU SCCs, the optional language shall not apply;
      7. In Clause 17 of the EU SCCs, Option 1 applies and the EU SCCs shall be governed by Irish law;
      8. In Clause 18(b) of the EU SCCs, disputes shall be resolved by the courts of Ireland;
      9. Annex I of the EU SCCs shall be deemed completed with the information set out in Exhibit A of this DPA;
      10. Annex II of the EU SCCs shall be deemed completed with the information set out in Exhibit B of this DPA.

   3. The parties agree that the EU SCCs as amended in clause 7.2 above, shall be adjusted as set out below where the FADP applies to any Restricted Transfer:

      1. The Swiss Federal Data Protection and Information Commissioner ("FDPIC") shall be the sole Supervisory Authority for Restricted Transfers exclusively subject to the FADP;
      2. Restricted Transfers subject to both the FADP and the EU GDPR, shall be dealt with by the EU Supervisory Authority named in Exhibit A of this DPA;
      3. The term 'member state' must not be interpreted in such a way as to exclude Data Subjects in Switzerland from the possibility of suing for their rights in their place of habitual residence (Switzerland) in accordance with Clause 18(c) of the EU SCCs;
      4. Where Restricted Transfers are exclusively subject to the FADP, all references to the GDPR in the EU SCCs are to be understood to be references to the FADP;
      5. Where Restricted Transfers are subject to both the FADP and the EU GDPR, all references to the GDPR in the EU SCCs are to be understood to be references to the FADP insofar as the Restricted Transfers are subject to the FADP;
      6. The Swiss SCCs also protect the Personal Data of legal entities until the entry into force of the revised FADP.

   4. The parties agree that the UK SCCs shall apply to Restricted Transfers from the UK and the UK SCCs shall be deemed entered into (and incorporated into this DPA by reference), as set out in Exhibit C of this DPA.

   5. In the event that any provision of this DPA contradicts directly or indirectly any SCCs, the provisions of the applicable SCCs shall prevail over the terms of the DPA.

8. Data Subject Access Requests

   1. The Controller may require correction, deletion, blocking and/or making available the Personal Data during or after termination of the Agreement. The Controller acknowledges and agrees that the Processor will process the request to the extent it is lawful and will reasonably fulfil such request in accordance with its standard operational procedures to the extent possible.
   2. In the event that the Processor receives a request from a Data Subject in relation to Personal Data, the Processor will refer the Data Subject to the Controller unless otherwise prohibited by law. The Controller shall reimburse the Processor for all costs incurred resulting from providing reasonable assistance in dealing with a Data Subject request. In the event that the Processor is legally required to respond to the Data Subject, the Controller will fully cooperate with the Processor as applicable.

9. Audit

   1. The Processor shall make available to the Controller all information reasonably necessary to demonstrate compliance with its processing obligations and allow for and contribute to audits and inspections.
   2. Any audit conducted under this DPA shall consist of examination of the most recent reports, certificates and/or extracts prepared by an independent auditor bound by confidentiality provisions similar to those set out in the Agreement. In the event that provision of the same is not deemed sufficient in the reasonable opinion of the Controller, the Controller may conduct a more extensive audit which shall be: (i) at the Controller's expense; (ii) limited in scope to matters specific to the Controller and agreed in advance; (iii) carried out during the Processor's usual business hours and upon reasonable notice which shall be not less than 4 weeks unless an identifiable material issue has arisen; and (iv) conducted in a way which does not interfere with the Processor's day-to-day business.
   3. This clause shall not modify or limit the rights of audit of the Controller, instead it is intended to clarify the procedures in respect of any audit undertaken pursuant thereto.
   4. Where the Processor holds a current SOC 2 Type 2 report or equivalent independent attestation, examination of such report shall be deemed to satisfy any audit request under clause 9.2 to the extent the matter requested is within its scope. The Processor will make such reports available upon written request, subject to a customary non-disclosure agreement, and may charge a reasonable administrative fee for their production depending on the Controller's subscription plan and the terms of the Agreement.

10. Personal Data Breach

    1. The Processor shall notify the Controller without undue delay after becoming aware of (and in any event within 48 hours of discovering) any breach of security leading to the accidental or unlawful destruction, loss, alteration or unauthorized disclosure or access to any Personal Data ("Personal Data Breach").
    2. Such notification shall include, to the extent reasonably available: (i) the nature of the Personal Data Breach, including where possible the categories and approximate number of Data Subjects and Personal Data records concerned; (ii) the likely consequences of the Personal Data Breach; and (iii) the measures taken or proposed to be taken to address the Personal Data Breach, including measures to mitigate its possible adverse effects.
    3. In the event of a Personal Data Breach, the Processor shall take all commercially reasonable measures to secure the Personal Data, to limit the effects of any Personal Data Breach, and to assist the Controller in meeting the Controller's obligations under applicable law, including the Controller's obligation to notify relevant Supervisory Authorities and affected Data Subjects.

11. Compliance, Cooperation and Response

    1. The Processor will notify the Controller promptly of any request or complaint regarding the processing of Personal Data, which adversely impacts the Controller, unless such notification is not permitted under applicable law or a relevant court order.
    2. The Processor may make copies of and/or retain Personal Data in compliance with any legal or regulatory requirement including, but not limited to, retention requirements.
    3. The Processor shall reasonably assist the Controller in meeting the Controller's obligation to carry out data protection impact assessments (DPIAs), taking into account the nature of the processing and the information available to the Processor.
    4. The Controller shall notify the Processor within a reasonable time, of any changes to applicable data protection laws, codes or regulations which may affect the contractual duties of the Processor. The Processor shall respond within a reasonable time frame in respect of any changes that need to be made to the terms of this DPA or to the technical and organizational measures to maintain compliance. If the Processor is unable to accommodate necessary changes, the Controller may terminate the part or parts of the Services which give rise to the non-compliance. To the extent that other parts of the Services provided are not affected by such changes, the provision of those Services shall remain unaffected.
    5. The Controller and the Processor and, where applicable, their representatives, shall cooperate, on request, with a Supervisory Authority in the performance of their respective obligations under this DPA and Data Protection Law.

12. Liability

    1. The limitations on liability set out in the Agreement apply to all claims made pursuant to any breach of the terms of this DPA.
    2. The parties agree that the Processor shall be liable for any breaches of this DPA caused by the acts and omissions or negligence of its Sub-processors to the same extent the Processor would be liable if performing the services of each Sub-processor directly under the terms of the DPA, subject to any limitations on liability set out in the terms of the Agreement.
    3. The parties agree that the Controller shall be liable for any breaches of this DPA caused by the acts and omissions or negligence of its Affiliates as if such acts, omissions or negligence had been committed by the Controller itself.
    4. The Controller shall not be entitled to recover more than once in respect of the same loss.

13. Term and Termination

    1. The Processor shall only process Personal Data for the term of the DPA. The term of this DPA shall commence on the Effective Date of the Agreement and this DPA shall terminate automatically together with termination or expiry of the Agreement.

14. Deletion and Return of Personal Data

    1. The Processor shall at the choice of the Controller, upon receipt of a written request received within 30 days of the end of the provision of the Services, delete or return Personal Data to the Controller. The Controller can also delete their account and all associated Personal Data themselves in the account management app. The Processor shall in any event delete all copies of Personal Data in its systems within 45 days of the effective date of termination of the Agreement or deactivation of the Customer's account unless applicable law or regulations require storage of the Personal Data after termination.

15. General

    1. This DPA sets out the entire understanding of the parties with regards to the subject matter herein.
    2. Should a provision of this DPA be invalid or become invalid then the legal effect of the other provisions shall be unaffected. A valid provision is deemed to have been agreed which comes closest to what the parties intended commercially and shall replace the invalid provision. The same shall apply to any omissions.
    3. Subject to any provision of the SCCs to the contrary, this DPA shall be governed by the laws of England and Wales. The courts of England shall have exclusive jurisdiction for the settlement of all disputes arising under this DPA.
    4. The parties agree that this DPA is incorporated into and governed by the terms of the Agreement.

Exhibit A: Parties, Scope, and Competent Authorities

List of Parties, Description of Processing and Transfer of Personal Data, Competent Supervisory Authority

A. LIST OF PARTIES

• The Exporter:
  • means the Customer.
  • Address: As set out for the Customer in the Agreement.
  • Contact person's name, position and contact details: As provided by the Customer in its account and used for notification and invoicing purposes.
  • Activities relevant to the data transferred under the SCCs: Use of the Services.
  • Signature and date: By entering into the Agreement, the Exporter is deemed to have signed the SCCs incorporated into this DPA and including their Annexes, as of the Effective Date of the Agreement.
  • Role: Controller.
  • Name of Representative (if applicable): Any UK or EU representative named in the Exporter's privacy policy.
• The Importer:
  • means the Parseur Pte. Ltd.
  • Address: 160 Robinson Road, #14-04 Singapore Business Federation Centre, Singapore (068914), Singapore.
  • Contact person's name, position and contact details: Sylvestre Dupont, Co-founder and CEO, [email protected] - Activities relevant to the data transferred under the SCCs: The provision of cloud computing solutions to the Exporter under which the Importer processes Personal Data upon the instructions of the Exporter in accordance with the terms of the Agreement.
  • Signature and date: By entering into the Agreement, the Importer is deemed to have signed the SCCs, incorporated into this DPA, including their Annexes, as of the Effective Date of the Agreement.
  • Role: Processor.
  • Name of Representative: DataRep, reachable by

    • sending an email to [email protected]

    • filling the contact form on https://www.datarep.com/parseur

    • mailing your enquiry to DataRep at the most convenient of the addresses listed below:

      Country	Address
      Austria	DataRep, City Tower, Brückenkopfgasse 1/6. Stock, Graz, 8020, Austria
      Belgium	DataRep, Rue des Colonies 11, Brussels, 1000
      Bulgaria	DataRep, 25 Vitosha blvd. Fl. 2, office 4, 1000, Sofia, Bulgaria
      Croatia	DataRep, Ground & 9th Floor, Hoto Tower, Savska cesta 32, Zagreb, 10000, Croatia
      Cyprus	DataRep, Victory House, 205 Archbishop Makarios Avenue, Limassol, 3030, Cyprus
      Czech Republic	DataRep, Platan Office, 28. Října 205/45, Floor 3&4, Ostrava, 70200, Czech Republic
      Denmark	DataRep, Lautruphøj 1-3, Ballerup, 2750, Denmark
      Estonia	DataRep, 2nd Floor, Tornimae 5, Tallinn, 10145, Estonia
      Finland	DataRep, Luna House, 5.krs, Mannerheimintie 12 B, Helsinki, 00100, Finland
      France	DataRep, 72 rue de Lessard, Rouen, 76100, France
      Germany	DataRep, 3rd and 4th floor, Altmarkt 10 B/D, Dresden, 01067, Germany
      Greece	DataRep, Ippodamias Sq. 8, 4th floor, Piraeus, Attica, Greece
      Hungary	DataRep, 1054 Honved street, 8 1/2, Budapest, Hungary
      Iceland	DataRep, Laugavegur 13, 101 Reykjavik, Iceland
      Ireland	DataRep, 77 Camden Street Lower, Dublin, D02 XE80, Ireland
      Italy	DataRep, Viale Giorgio Ribotta 11, Piano 1, Rome, Lazio, 00144, Italy
      Latvia	DataRep, 4th & 5th floors, 14 Terbatas Street, Riga, LV-1011, Latvia
      Liechtenstein	DataRep, City Tower, Brückenkopfgasse 1/6. Stock, Graz, 8020, Austria
      Lithuania	DataRep, 44A Gedimino Avenue, 01110 Vilnius, Lithuania
      Luxembourg	DataRep, BPM 335368, Banzelt 4 A, 6921, Roodt-sur-Syre, Luxembourg
      Malta	DataRep, Tower Business Centre, 2nd floor, Tower Street, Swatar, BKR4013, Malta
      Netherlands	DataRep, De Nieuwe Erven 3 Unit – 15162, 5431 NV Cuijk, Netherlands
      Norway	DataRep, C.J. Hambros Plass 2c, Oslo, 0164, Norway
      Poland	DataRep, Budynek Fronton ul Kamienna 21, Krakow, 31-403, Poland
      Portugal	DataRep, Torre de Monsanto, Rua Afonso Praça 30, 7th floor, Algès, Lisbon, 1495-061, Portugal
      Romania	DataRep, 15 Piaţa Charles de Gaulle, nr. 1-T, Bucureşti, Sectorul 1, 011857, Romania
      Slovakia	DataRep, Apollo Business Centre II, Block E / 9th floor, 4D Prievozska, Bratislava, 821 09, Slovakia
      Slovenia	DataRep, Trg. Republike 3, Floor 3, Ljubljana, 1000, Slovenia
      Spain	DataRep, Calle de Manzanares 4, Madrid, 28005, Spain
      Sweden	DataRep, S:t Johannesgatan 2, 4th floor, Malmo, SE - 211 46, Sweden
      Switzerland	DataRep, Leutschenbachstrasse 95, Zurich, 8050, Switzerland
      United Kingdom	DataRep, 107-111 Fleet Street, London, EC4A 2AB, United Kingdom

    • When addressing your requests by post, make sure to address them to "DataRep" and not Parseur directly; communications addressed to Parseur directly at DataRep's contact locations will likely not be received.

B. DESCRIPTION OF PROCESSING AND TRANSFERS

• Categories of Data Subjects:

  Employees, agents, advisors, consultants, freelancers of the Controller (who are natural persons). Authorized Users, Affiliates and other participants authorized by the Controller to access or use the Services in accordance with the terms of the Agreement.

  Prospects, customers, clients, business partners and vendors of the Controller (who are natural persons) and individuals with whom those end users communicate with by email and/or other messaging media. Employees or contact persons of Controller's prospects, customers, clients, business partners and vendors.

  Suppliers and service providers of the Controller.

  Other individuals to the extent identifiable in the context of documents sent by the Controller for processing.

• Categories of Personal Data:

  The Controller may submit any Personal Data to the Services, the extent of which is determined and controlled by the Controller. The Processor does not assess the categories of data sent by the Controller. It is for the Controller to decide which category of data they wish to process as part of this agreement.

• Sensitive Data:

  Sensitive data may be contained in the data added to the Services by the Controller, Affiliates or Authorized Users or in the content of any documents uploaded by the Controller.

  This may include but is not limited to the following special categories of Personal Data:

  • personal Data revealing racial or ethnic origin
  • political opinions,
  • religious or philosophical beliefs
  • trade union membership
  • the processing of genetic data
  • biometric data for the purpose of uniquely identifying a natural person
  • data concerning health or data concerning a natural person's sex life or sexual orientation
  • personal data relating to criminal convictions and offense

• The frequency of the processing and transfer (e.g. whether the data is transferred on a one-off or continuous basis):

  Continuous basis for the duration of the Agreement.

• Nature of the processing:

  Processing operations include but are not limited to:

  • data extraction of types of data determined by the Controller from documents uploaded into the Services by the Controller, its Affiliates and Authorized Users, performed using template-based methods, artificial-intelligence methods, or a combination of both. The Controller may configure its account to restrict extraction to template-based methods only.

• Purpose(s) of the data transfer and further processing:

  Personal Data is transferred to sub-contractors who need to process some of the Personal Data in order to provide their services to the Processor as part of the Services provided by the Processor to the Controller.

• The period for which the Personal Data will be retained, or, if that is not possible, the criteria used to determine that period:

  Unless agreed otherwise in writing, for the duration of the Agreement, subject to clause 14 of the DPA.

• For transfers to (Sub-) processors, also specify subject matter, nature and duration of the processing:

  The Sub-processor list published at: https://parseur.com/dpa-subprocessors sets out the Personal Data processed by each Sub-processor and the services provided by each Sub-processor.

C. COMPETENT SUPERVISORY AUTHORITY

Identify the competent supervisory authority/ies (e.g. in accordance with Clause 13 of the SCCs):

• Where the EU GDPR applies, the Irish Data Protection Authority - Data Protection Commission (DPC).
• Where the UK GDPR applies, the UK Information Commissioner's Office (ICO).
• Where the FADP applies, the Swiss Federal Data Protection and Information Commissioner (FDPIC).

Exhibit B: Technical and Organizational Security Measures

Including Technical and Organizational Measures to Ensure the Security of Data

Below is a description of the technical and organizational measures implemented by the Processor (including any relevant certifications) to ensure an appropriate level of security, taking into account the nature, scope, context and purpose of the processing, and the risks for the rights and freedoms of natural persons. Where applicable this Exhibit B will serve as Annex II to the SCCs.

• Measures of encryption of Personal Data:

  Customer Data is encrypted at rest and in transit using industry-standard algorithms.

• Measures for ensuring ongoing confidentiality, integrity, availability and resilience of processing systems and services:

  Access to Personal Data is governed by role-based access control following least-privilege and need-to-know principles. Multi-factor authentication is enforced for staff access to production systems and administrative interfaces. Endpoint devices used by staff with access to Personal Data are centrally managed, with disk encryption, anti-malware protection, and automatic session locking enforced.

• 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:

  Production applications can be redeployed in alternate geographic regions through automated infrastructure tooling. Automated backups are taken regularly, stored encrypted in geographically separated locations, and isolated from production systems. The Processor maintains documented Business Continuity, Disaster Recovery, and Data Backup and Recovery policies, with recovery procedures tested at least annually.

• Processes for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures in order to ensure the security of the processing:

  The Processor maintains a documented Vulnerability and Patch Management policy covering continuous automated scanning of production infrastructure, static analysis and dependency monitoring of application code, and annual penetration testing performed by an independent firm. Identified vulnerabilities are remediated within timeframes commensurate with their severity. The Processor's overall security control environment is also independently assessed in accordance with clause 9.4 of this DPA.

• Measures for user identification and authorization:

  Staff authentication to internal systems is governed by the Processor's documented Password Policy, requiring strong, unique credentials managed through a corporate password manager and multi-factor authentication for sensitive systems. Administrative access to production systems is mediated through a managed access gateway with key-based authentication. Customer Authorized Users may access the Services using credentials protected by a salted hash generated through an industry-standard key-stretching algorithm, and may additionally enable multi-factor authentication or single sign-on through their account settings.

• Measures for the protection of data during transmission:

  All data transmitted between Controllers, Authorized Users, the Services, and third-party integrations is protected by modern transport-layer encryption; deprecated protocols are disabled.

• Measures for the protection of data during storage:

  Personal Data is stored on third-party infrastructure operated by sub-processors listed at https://parseur.com/dpa-subprocessors. Customer Data is encrypted at rest using industry-standard algorithms.

• Measures for ensuring physical security of locations at which Personal Data are processed:

  Personal Data is processed in third-party data centres that enforce strict physical access controls, security personnel monitoring, and separated zones for sensitive equipment. The Processor does not operate its own data centres.

• Measures for ensuring events logging:

  Audit logs are collected centrally from production systems and applications in accordance with the Processor's documented Audit Log Management and Data Management policies. High-risk events are reviewed in accordance with the Processor's documented Incident Response Policy, which covers detection, classification, containment, eradication, recovery, and post-incident review.

• Measures for ensuring system configuration, including default configuration:

  System configuration is managed through infrastructure-as-code and version-controlled. Application secrets are stored in tightly access-controlled secret management systems separate from source code repositories.

• Measures for internal IT and IT security governance and management:

  The Processor maintains a suite of documented information security policies, including (without limitation) policies covering Access Management, Asset Management, Change Management, Data Management, and Secure Development. Production changes follow a documented change management process requiring peer review, segregation of duties between approval and implementation, and pre-production testing. Development environments are isolated from production Customer Data, and software is developed in accordance with secure coding standards. Customer Data is logically segregated from data of other customers.

• Measures for certification/assurance of processes and products:

  The Processor utilises third-party data centres that maintain current independent security attestations (such as ISO 27001 or SOC 2 Type 2). The Processor's own security control environment is independently assessed; reports are made available in accordance with clause 9.4 of this DPA.

• Measures for ensuring data minimisation:

  The Processor maintains a Data Management Policy including data classification, a data inventory, and data-flow mapping. Customer Data is processed only to the extent necessary to provide the Services in accordance with this DPA.

• Measures for ensuring data quality:

  All Customer Data is provided by the Controller. The Processor does not assess the quality of the data provided by the Controller. The Services include reporting tools to help the Controller understand and validate the data that is stored.

• Measures for ensuring limited data retention:

  Retention of Customer Data is configurable by the Controller through the Services. Personal Data deleted by the Controller is removed from the Processor's active systems immediately and from all backups within 45 days. Accounts inactive for more than one year are deleted in accordance with the Processor's documented Data Management Policy.

• Measures for ensuring accountability:

  The Processor maintains documented information security policies that are reviewed at least annually and acknowledged by relevant personnel. The Processor performs an annual information security risk assessment in accordance with its documented Risk Management Policy. Staff access to systems is reviewed at least annually. The Processor maintains documented Onboarding, Offboarding, and Reference Check policies governing the lifecycle of staff access and pre-employment screening. The Processor maintains a documented Vendor Management policy covering the assessment and ongoing monitoring of sub-processors and other third-party service providers.

• Measures for allowing data portability and ensuring erasure:

  The Services include built-in tools that allow the Controller to export and permanently erase Customer Data.

• Measures to be taken by the (Sub-) processor to be able to provide assistance to the Controller (and, for transfers from a Processor to a Sub-processor, to the Data Exporter):

  Personal Data is transferred to sub-processors only under a written contract that imposes obligations materially equivalent to those of this DPA. For transfers outside the EEA, an appropriate transfer mechanism is in place in accordance with applicable Data Protection Law, as detailed in clause 7 of this DPA.

Exhibit C: International Data Transfer Addendum

International Data Transfer Addendum to the EU Commission Standard Contractual Clauses

VERSION B1.0, in force 21 March 2022

This Addendum has been issued by the Information Commissioner for Parties making Restricted Transfers. The Information Commissioner considers that it provides Appropriate Safeguards for Restricted Transfers when it is entered into as a legally binding contract.

Part 1: Tables

Table 1: Parties

Start date: The date set out in Annex I of the Approved EU SCCs.

The Parties

• Importer (who sends the Restricted Transfer)
• Exporter (who receives the Restricted Transfer)

Key Contacts

Signature (if required for the purposes of Section 2): See the Agreement.

Table 2: Selected SCCs, Modules and Selected Clauses

Addendum EU SCCs: [X] the Approved EU SCCs, including the Appendix Information and with only the following modules, clauses or optional provisions of the Approved EU SCCs brought into effect for the purposes of this Addendum:

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 Addendum is set out in:

• Annex 1A: List of Parties: As set out in Annex I of the Approved EU SCCs
• Annex 1B: Description of Transfer: As set out in Annex I of the Approved EU SCCs
• Annex II: Technical and organizational measures including technical and organizational measures to ensure the security of the data: As set out in Annex II of the Approved EU SCCs

Table 4: Ending this Addendum when the Approved Addendum Changes

Which Parties may end this Addendum as set out in Section 19:

• Importer
• Exporter

Part 2: Mandatory Clauses

Entering into this Addendum

• 1. Each Party agrees to be bound by the terms and conditions set out in this Addendum, in exchange for the other Party also agreeing to be bound by this Addendum.
• 2. Although Annex 1A and Clause 7 of the Approved EU SCCs require signature by the Parties, for the purpose of making Restricted Transfers, the Parties may enter into this 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 Addendum. Entering into this Addendum will have the same effect as signing the Approved EU SCCs and any part of the Approved EU SCCs.

Interpretation of this Addendum

• 3. Where this 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:

  • Addendum: This International Data Transfer Addendum which is made up of this Addendum incorporating the Addendum EU SCCs.
  • Addendum EU SCCs: The version(s) of the Approved EU SCCs which this Addendum is appended to, as set out in Table 2, including the Appendix Information.
  • Appendix Information: As set out in Table 3.
  • Appropriate Safeguards: 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 a Restricted Transfer relying on standard data protection clauses under Article 46(2)(d) UK GDPR.
  • Approved Addendum: 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 it is revised under Section 18.
  • Approved EU SCCs : The Standard Contractual Clauses set out in the Annex of Commission Implementing Decision (EU) 2021/914 of 4 June 2021.
  • ICO: The Information Commissioner.
  • Restricted Transfer: A transfer which is covered by Chapter V of the UK GDPR.
  • UK : The United Kingdom of Great Britain and Northern Ireland.
  • UK Data Protection Laws: 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: As defined in section 3 of the Data Protection Act 2018.

• 4. This Addendum must always be interpreted in a manner that is consistent with UK Data Protection Laws and so that it fulfils the Parties' obligation to provide the Appropriate Safeguards.

• 5. If the provisions included in the Addendum EU SCCs amend the Approved SCCs in any way which is not permitted under the Approved EU SCCs or the Approved Addendum, such amendment(s) will not be incorporated in this Addendum and the equivalent provision of the Approved EU SCCs will take their place.

• 6. If there is any inconsistency or conflict between UK Data Protection Laws and this Addendum, UK Data Protection Laws applies.

• 7. If the meaning of this Addendum is unclear or there is more than one meaning, the meaning which most closely aligns with UK Data Protection Laws applies.

• 8. 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 this Addendum has been entered into.

Hierarchy

• 9. 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 Restricted Transfers, the hierarchy in Section 10 will prevail.
• 10. Where there is any inconsistency or conflict between the Approved Addendum and the Addendum EU SCCs (as applicable), the Approved Addendum overrides the Addendum EU SCCs, except where (and in so far as) the inconsistent or conflicting terms of the Addendum EU SCCs provides greater protection for data subjects, in which case those terms will override the Approved Addendum.
• 11. Where this Addendum incorporates Addendum EU SCCs which have been entered into to protect transfers subject to the General Data Protection Regulation (EU) 2016/679 then the Parties acknowledge that nothing in this Addendum impacts those Addendum EU SCCs.

Incorporation of and changes to the EU SCCs

• 12. This Addendum incorporates the Addendum EU SCCs which are amended to the extent necessary so that:

  • a. 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;
  • b. Sections 9 to 11 override Clause 5 (Hierarchy) of the Addendum EU SCCs; and
  • c. this Addendum (including the Addendum 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, in each case unless the laws and/or courts of Scotland or Northern Ireland have been expressly selected by the Parties.

• 13. Unless the Parties have agreed alternative amendments which meet the requirements of Section 12, the provisions of Section 15 will apply.

• 14. No amendments to the Approved EU SCCs other than to meet the requirements of Section 12 may be made.

• 15. The following amendments to the Addendum EU SCCs (for the purpose of Section 12) are made:

  • a. References to the "Clauses" means this Addendum, incorporating the Addendum EU SCCs;
  • b. 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";
  • c. 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.";
  • d. 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";
  • e. 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;"
  • f. 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;
  • g. References to Regulation (EU) 2018/1725 are removed;
  • h. References to the "European Union", "Union", "EU", "EU Member State", "Member State" and "EU or Member State" are all replaced with the "UK";
  • i. The reference to "Clause 12(c)(i)" at Clause 10(b)(i) of Module one, is replaced with "Clause 11(c)(i)";
  • j. Clause 13(a) and Part C of Annex I are not used;
  • k. The "competent supervisory authority" and "supervisory authority" are both replaced with the "Information Commissioner";
  • l. 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;";
  • m. Clause 17 is replaced with: "These Clauses are governed by the laws of England and Wales.";
  • n. Clause 18 is replaced with: "Any dispute arising from these Clauses shall be resolved by the courts of England and Wales. 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."; and
  • o. The footnotes to the Approved EU SCCs do not form part of the Addendum, except for footnotes 8, 9, 10 and 11

Amendments to this Addendum

• 16. The Parties may agree to change Clauses 17 and/or 18 of the Addendum EU SCCs to refer to the laws and/or courts of Scotland or Northern Ireland.

• 17. If the Parties wish to change the format of the information included in Part 1: Tables of the Approved Addendum, they may do so by agreeing to the change in writing, provided that the change does not reduce the Appropriate Safeguards.

• 18. From time to time, the ICO may issue a revised Approved Addendum which:

  • a. makes reasonable and proportionate changes to the Approved Addendum, including correcting errors in the Approved Addendum; and/or
  • b. reflects changes to UK Data Protection Laws;
  • The revised Approved Addendum will specify the start date from which the changes to the Approved Addendum are effective and whether the Parties need to review this Addendum including the Appendix Information. This Addendum is automatically amended as set out in the revised Approved Addendum from the start date specified.

• 19. If the ICO issues a revised Approved Addendum under Section , if any Party selected in Table 4 "Ending the Addendum when the Approved Addendum changes", will as a direct result of the changes in the Approved Addendum have a substantial, disproportionate and demonstrable increase in:

  • a. its direct costs of performing its obligations under the Addendum; and/or
  • b. its risk under the 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 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 Addendum.

• 20. The Parties do not need the consent of any third party to make changes to this Addendum, but any changes must be made in accordance with its terms.

Exhibit D: CCPA Addendum

California Consumer Privacy Act Addendum

This Exhibit D applies only where the CCPA applies to the processing of Personal Data by the Processor on behalf of the Controller.

• 1. For the purposes of this Exhibit D, the Processor acts as a "Service Provider" as defined by the CCPA. The terms "Business", "Business Purpose", "Commercial Purpose", "Personal Information", "Sell", "Share" and "Consumer" shall have the meanings given to them in the CCPA.

• 2. The Processor shall not: (i) sell or share (as those terms are defined by the CCPA) Personal Data; (ii) combine Personal Data received from or on behalf of the Controller with Personal Data received from or on behalf of any other person or entity, or collected independently by the Processor, except as permitted by the CCPA for the Processor's own business operations that are specified in the Agreement; (iii) retain, use, or disclose Personal Data for any purpose other than the Business Purpose specified in the Agreement and as permitted by the CCPA.

• 3. The Processor certifies that it understands and will comply with the restrictions set out in this Exhibit D and the requirements of the CCPA applicable to Service Providers.

• 4. The Processor shall allow the Controller to take reasonable and appropriate steps to help ensure that the Processor uses Personal Data in a manner consistent with the Controller's obligations under the CCPA.

• 5. The Processor shall notify the Controller if it determines that it can no longer meet its obligations under the CCPA.

Exhibit E: PDPA Addendum

Singapore Personal Data Protection Act Addendum

This Exhibit E applies only where the PDPA applies to the processing of Personal Data by the Processor on behalf of the Controller.

• 1. For the purposes of this Exhibit E, the Processor acts as a "Data Intermediary" as defined under Section 4(2) of the PDPA, processing Personal Data on behalf of and for the purposes of the Controller.

• 2. The Processor shall protect Personal Data in its possession or under its control by making reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks, in accordance with Section 24 of the PDPA.

• 3. Where Personal Data is transferred outside Singapore by the Processor or its Sub-processors, the Processor ensures that the recipient provides a standard of protection to the Personal Data that is comparable to the protection under the PDPA, through binding contractual obligations including this DPA and agreements with Sub-processors, in accordance with Section 26 of the PDPA.

• 4. In the event of a Personal Data Breach that constitutes a "notifiable data breach" under Section 26A of the PDPA (i.e. a breach that results in or is likely to result in significant harm to affected individuals, or is of a significant scale affecting 500 or more individuals), the Processor shall notify the Controller in sufficient time to enable the Controller to comply with its obligation to notify the Personal Data Protection Commission ("PDPC") within 3 business days of assessing the breach to be notifiable.

• 5. The Processor shall make its data protection policies available upon request and shall ensure that its employees who handle Personal Data receive appropriate training on the Processor's data protection obligations under the PDPA.

Last updated on August 12th, 2026