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DATA PROCESSING ADDENDUM
Based on the General Data Protection Regulation (GDPR) and European Commission Decision 2021/914/EU -
Standard Contractual Clauses
This Data Processing Addendum (“DPA”) forms part of the Master Subscription Agreement (or other such titled
written or electronic agreement addressing the same subject matter) between Okta and Customer for the purchase
of online identity-as-a-service and access management services (including related Okta offline or mobile
components) from Okta (identified collectively either as the “Service” or otherwise in the applicable agreement,
and hereinafter defined as the “Service”), wherein such agreement is hereinafter defined as the “Agreement,” and
whereby this DPA reflects the parties’ agreement with regard to the Processing of Personal Data. Customer enters
into this DPA on behalf of itself and, to the extent required under applicable Data Protection Laws and
Regulations, in the name and on behalf of its Authorized Affiliates, if and to the extent Okta processes Personal
Data for which such Authorized Affiliates qualify as the Controller or a Processor. All capitalized terms not
defined herein shall have the meaning set forth in the Agreement. In providing the Service to Customer pursuant
to the Agreement, Okta may Process Personal Data on behalf of Customer, and the parties agree to comply with
the following provisions with respect to any Personal Data.
This DPA is consists of distinct parts: (1) this body and its set of definitions and provisions, and (2) the Standard
Contractual Clauses and Annexes I, II and III (if applicable). Please note that the Controller-to-Processor and
Processor-to-Processor Standard Contractual Clauses are included by reference and their full text, including an
Annex III addressing data transfers with Switzerland and the United Kingdom, is available via a link in the
definitions of this DPA.
INSTRUCTIONS ON HOW TO EXECUTE THIS DPA WITH OKTA
1. This DPA has been pre-signed on behalf of Okta, Inc., as the data importer.
2. To complete this DPA, Customer must complete the information in the signature box and sign on Page 8.
3. Customer must send the completed and signed DPA to Okta by email, indicating the Customer’s full entity
name (as set out on the applicable Okta Order Form or invoice) in the body of the email, to DPA@okta.com.
Upon receipt of the validly-completed DPA by Okta at this email address, this DPA shall come into effect
and legally bind the parties.
APPLICATION OF THIS DPA
If the Customer entity signing this DPA is a party to the Agreement, then this DPA is an addendum to, and forms
part of, the Agreement. In such case, the Okta entity (i.e., either Okta, Inc. or a subsidiary of Okta, Inc.) that is
party to the Agreement is party to this DPA.
If the Customer entity signing this DPA has executed an Order Form with Okta or its Affiliate pursuant to the
Agreement, but is not itself a party to the Agreement, then this DPA is an addendum to that Order Form and
applicable renewal Order Forms, and the Okta entity that is a party to such Order Form is a party to this DPA.
If the Customer entity signing this DPA is neither a party to an Order Form nor the Agreement, then this DPA is
not valid and therefore is not legally binding. Such entity should request that the Customer entity who is a party
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to the Agreement executes this DPA.
DPA DEFINITIONS
“Affiliate” means any entity that directly or indirectly controls, is controlled by, or is under common control with
the Customer entity signing this Agreement, or with Okta, Inc., as the case may be. "Control," for purposes of
this definition, means direct or indirect ownership or control of more than 50% of the voting interests of the
subject entity.
“Authorized Affiliate” means any of Customer's Affiliate(s) which (a) is subject to the data protection laws and
regulations of the European Union, the European Economic Area and/or their member states, Switzerland and/or
the United Kingdom, and (b) is permitted to use the Service pursuant to the Agreement between Customer and
Okta, but has not signed its own Order Form with Okta and is not a "Customer" as defined under the Agreement.
“CCPA” means the California Consumer Privacy Act, California Civil Code sections 1798.100 et seq., and its
implementing regulations.
“Controller” means the entity which determines the purposes and means of the Processing of Personal Data.
“Controller to Processor Standard Contractual Clauses” means the agreement executed by and between Customer
acting as Controller and Okta acting as Processor and included herein, pursuant to the European Commission’s
Implementing Decision (EU) 2021/914 of 4 June 2021 on Standard Contractual Clauses for the transfer of
personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the
Council. The Controller to Processor Standard Contractual Clauses are currently available here.
“Customer Data” means all electronic data submitted by or on behalf of Customer, or an Authorized Affiliate, to
the Service.
“Data Protection Laws and Regulations” means all laws and regulations, including laws and regulations of the
European Union, the European Economic Area and their member states, Switzerland, the United Kingdom, and
the United States and its states, applicable to the Processing of Personal Data under the Agreement.
“Data Subject” means the identified or identifiable person to whom Personal Data relates.
“GDPR” means the 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, and repealing Directive 95/46/EC (General Data Protection Regulation).
“Personal Data” means any information relating to (i) an identified or identifiable natural person and, (ii) an
identified or identifiable legal entity (where such information is protected similarly as personal data or personally
identifiable information under applicable Data Protection Laws and Regulations), where for each (i) or (ii), such
data is Customer Data.
“Processing” (including its root word, “Process”) means any operation or set of operations which is performed
upon Personal Data, whether or not by automatic means, such as collection, recording, organization, structuring,
storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or
otherwise making available, alignment or combination, restriction, erasure or destruction.
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“Processor” means the entity which Processes Personal Data on behalf of the Controller.
“Trust & Compliance Documentation” means the Documentation applicable to the specific Service purchased by
Customer, as may be updated periodically, and accessible via Okta’s website at www.okta.com/agreements , or
as otherwise made reasonably available by Okta.
“Okta” means the Okta entity which is a party to this DPA, as specified in the section “Application of this DPA”
above, being Okta, Inc., a company incorporated in Delaware and its primary address as 100 First Street, San
Francisco California 94105, USA, or an Affiliate of Okta, as applicable.
“Okta Group” means Okta and its Affiliates engaged in the Processing of Personal Data.
“Standard Contractual Clauses” means either the Controller to Processor Standard Contractual Clauses or the
Processor to Processor Standard Contractual Clauses, as currently available here.
“Processor to Processor Standard Contractual Clauses “means the agreement executed by and between Customer
acting as a Processor acting on behalf of a Controller and Okta acting as a Processor on behalf of Customer
pursuant to the European Commission’s Implementing Decision (EU) 2021/914 of 4 June 2021 on Standard
Contractual Clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of
the European Parliament and of the Council. The Processor to Processor Standard Contractual Clauses are
currently available here.
“Sub-processor” means any Processor engaged by Okta or a member of the Okta Group.
“Supervisory Authority” means an independent public authority which is established by an EU Member State
pursuant to the GDPR.
DPA TERMS
Okta and the signatory below at the address below (“Customer”) hereby enter into this DPA effective as of the
last signature date below. This DPA is incorporated into and forms part of the Agreement.
1. Provision of the Service. Okta provides the Service to Customer under the Agreement. In connection
with the Service, the parties anticipate that Okta may Process Customer Data that contains Personal Data relating
to Data Subjects.
2. The Parties’ Roles. The parties agree that with regard to the Processing of Personal Data, Okta acts as
Processor on behalf of the Customer, which may act either as a Controller or a Processor,, and that Okta or
members of the Okta Group will engage Sub-processors pursuant to the requirements of this DPA.
3. Customer Responsibilities. Customer shall, in its use of the Service, Process Personal Data in accordance
with the requirements of Data Protection Laws and Regulations, including any applicable requirements to provide
notice to Data Subjects of the use of Okta as Processor. For the avoidance of doubt, Customer’s instructions for
the Processing of Personal Data shall comply with Data Protection Laws and Regulations. Customer shall have
sole responsibility for the accuracy, quality, and legality of Personal Data and the means by which Customer
acquired Personal Data. Customer specifically acknowledges that its use of the Service will not violate the rights
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of any Data Subject that has opted-out from sales or other disclosures of Personal Data, to the extent applicable
under the CCPA.
4. Processing Purposes. Okta shall keep Personal Data confidential and shall only Process Personal Data
on behalf of and in accordance with Customer’s documented instructions for the following purposes: (i)
Processing in accordance with the Agreement and applicable Order Form(s); (ii) Processing initiated by Users in
their use of the Service; and (iii) Processing to comply with other documented, reasonable instructions provided
by Customer (for example, via email) where such instructions are consistent with the terms of the Agreement.
Okta shall not be required to comply with or observe Customer’s instructions if such instructions would violate
the GDPR or other EU law or EU member state data protection provisions.
5. Scope of Processing. The subject-matter of Processing of Personal Data by Okta is the performance of
the Service pursuant to the Agreement. The duration of the Processing, the nature and purpose of the Processing,
the types of Personal Data and categories of Data Subjects Processed under this DPA are further specified in
Annex I to the Standard Contractual Clauses attached to this DPA.
6. Data Subject Requests. To the extent legally permitted, Okta shall promptly notify Customer if Okta
receives a request from a Data Subject to exercise the Data Subject's right of access, right to rectification,
restriction of Processing, erasure (“right to be forgotten”), data portability, object to the Processing, or its right
not to be subject to an automated individual decision making (“Data Subject Request”). Factoring into account
the nature of the Processing, Okta shall assist Customer by appropriate organizational and technical measures,
insofar as this is possible, for the fulfilment of Customer’s obligation to respond to a Data Subject Request under
Data Protection Laws and Regulations. In addition, to the extent Customer, in its use of the Service, does not have
the ability to address a Data Subject Request, Okta shall, upon Customer’s request, provide commercially-
reasonable efforts to assist Customer in responding to such Data Subject Request, to the extent that Okta is legally
authorized to do so, and the response to such Data Subject Request is required under Data Protection Laws and
Regulations. To the extent legally permitted, Customer shall be responsible for any costs arising from Okta’s
provision of such assistance.
7. Okta Personnel. Okta shall ensure that its personnel engaged in the Processing of Personal Data are
informed of the confidential nature of the Personal Data, have received appropriate training regarding their
responsibilities, and have executed written confidentiality agreements. Okta shall take commercially-reasonable
steps to ensure the reliability of any Okta personnel engaged in the Processing of Personal Data. Okta shall ensure
that Okta’s access to Personal Data is limited to those personnel assisting in the provision of the Service in
accordance with the Agreement.
8. Data Protection Officer. Members of the Okta Group have appointed a data protection officer. The
appointed person may be reached at privacy@okta.com.
9. Okta’s Sub-processors. Customer has instructed or authorized the use of Sub-processors to assist Okta
with respect to the performance of Okta's obligations under the Agreement and Okta agrees to be responsible for
the acts or omissions of such Sub-processors to the same extent as Okta would be liable if performing the services
of the Sub-processors under the terms of the Agreement.
9.1. List of Okta’s Sub-processors. A list of Okta’s current Sub-processors, including a description of their
processing activities and locations, is made available on Okta’s Agreements webpage (accessible via
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www.okta.com/agreements under the “Trust & Compliance Documentation” link). Customer
acknowledges and agrees that (a) Okta’s Affiliates may be retained as Sub-processors; and (b) Okta and
Okta’s Affiliates respectively may engage third-party Sub-processors in connection with the provision of
the Service. On Okta’s Agreements webpage (accessible via www.okta.com/agreements under the “Trust
& Compliance Documentation” link), Customer may find a mechanism to subscribe to notifications of
new Sub-processors for each applicable Service, to which Customer shall subscribe, and if Customer
subscribes, Okta shall provide notification of a new Sub-processor(s) before authorizing any new Sub-
processor(s) to process Personal Data in connection with the provision of the applicable Service.
9.2. Right to object to a new Sub-processor. In order to exercise its right to object to Okta’s use of a new
Sub-processor, Customer shall notify Okta promptly in writing within ten (10) business days after receipt
of Okta’s notice in accordance with the mechanism set out above. In the event Customer objects to a new
Sub-processor, and that objection is not unreasonable, Okta will use reasonable efforts to make available
to Customer a change in the Service or recommend a commercially-reasonable change to Customer’s
configuration or use of the Service to avoid Processing of Personal Data by the objected-to new Sub-
processor without unreasonably burdening the Customer. If Okta is unable to make available such change
within a reasonable time period, which shall not exceed thirty (30) days, Customer may terminate the
applicable Order Form(s) with respect only to those aspects of the Service which cannot be provided by
Okta without the use of the objected-to new Sub-processor by providing written notice to Okta. Okta will
refund Customer any prepaid fees covering the remainder of the term of such Order Form(s) following
the effective date of termination with respect to such terminated Service.
9.3. Sub-processors and the Standard Contractual Clauses. Customer acknowledges and agrees that Okta
may engage Sub-processors as described in this Section for the fulfilment of Okta’s obligations under
Clause 9(a) of the Standard Contractual Clauses. The parties agree that the copies of the Sub-processor
agreements that must be provided by Okta to Customer pursuant to Clause 9(c) of the Standard
Contractual Clauses may have all commercial information, or clauses unrelated to the Standard
Contractual Clauses or their equivalent, removed by Okta beforehand to protect business secrets or other
confidential information; and, that such copies will be provided by Okta, in a manner to be determined
in its discretion, only upon request by Customer.
10. Liability for Sub-processors. Okta shall be liable for the acts and omissions of its Sub-processors to the
same extent Okta would be liable if performing the services of each Sub-processor directly under the terms of
this DPA, except as otherwise set forth in the Agreement.
11. Security Measures. Okta shall maintain appropriate organizational and technical measures for protection
of the security (including protection against unauthorized or unlawful Processing, and against unlawful or
accidental destruction, alteration or damage or loss, unauthorized disclosure of, or access to, Customer Data),
confidentiality, and integrity of Customer Data, as set forth in Okta’s applicable Trust & Compliance
Documentation. Okta regularly monitors compliance with these measures. Okta will not materially decrease the
overall security of the Service during a subscription term.
12. Third-Party Certifications and Audit Results. Okta has attained the third-party certifications and audit
results set forth in the Trust & Compliance Documentation. Upon Customer’s written request at reasonable
intervals, and subject to the confidentiality obligations set forth in the Agreement, Okta shall make available to
Customer a copy of Okta’s then most recent third-party certifications or audit results, as applicable.
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13. Notifications Regarding Customer Data. Okta has in place reasonable and appropriate security incident
management policies and procedures, as specified in the Trust & Compliance Documentation and shall notify
Customer without undue delay after becoming aware of the unlawful or accidental destruction, alteration or
damage or loss, unauthorized disclosure of, or access to, Customer Data, including Personal Data, transmitted,
stored or otherwise Processed by Okta or its Sub-processors of which Okta becomes aware (hereinafter, a
“Customer Data Incident”). Okta shall make reasonable efforts to identify the cause of such Customer Data
Incident, and take those steps as Okta deems necessary and reasonable in order to remediate the cause of such a
Customer Data Incident, to the extent that the remediation is within Okta’s reasonable control. The obligations
set forth herein shall not apply to incidents that are caused by either Customer or Customer’s Users.
14. Return of Customer Data. Okta shall return Customer Data to Customer and, to the extent allowed by
applicable law, delete Customer Data in accordance with the procedures and time periods specified in the Trust
& Compliance Documentation, unless the retention of the data is requested from Okta according to mandatory
statutory laws.
15. Authorized Affiliates. The parties agree that, by executing the DPA, the Customer enters into the DPA
on behalf of itself and, as applicable, in the name and on behalf of its Authorized Affiliate(s), thereby establishing
a separate DPA between Okta and each such Authorized Affiliate, subject to the provisions of the Agreement.
Each Authorized Affiliate agrees to be bound by the obligations under this DPA and, to the extent applicable, the
Agreement. An Authorized Affiliate is not and does not become a party to the Agreement, and is only a party to
the DPA. All access to and use of the Service by Authorized Affiliate(s) must comply with the terms and
conditions of the Agreement and any violation thereof by an Authorized Affiliate shall be deemed a violation by
Customer.
16. Communications. The Customer that is the contracting party to the Agreement shall remain responsible
for coordinating all communication with Okta under this DPA, and shall be entitled to transmit and receive any
communication in relation to this DPA on behalf of its Authorized Affiliate(s).
17. Exercise of Rights. Where an Authorized Affiliate becomes a party to the DPA, it shall to the extent
required under applicable Data Protection Laws and Regulations be entitled to exercise the rights and seek
remedies under this DPA, except where applicable Data Protection Laws and Regulations require the Authorized
Affiliate to exercise a right or seek any remedy under this DPA against Okta directly by itself, the parties agree
that (i) solely the Customer that is the contracting party to the Agreement shall exercise any such right or seek
any such remedy on behalf of the Authorized Affiliate, and (ii) the Customer that is the contracting party to the
Agreement shall exercise any such rights under this DPA in a combined manner for all of its Authorized Affiliates
together, instead of doing so separately for each Authorized Affiliate.
18. Liability. Each party’s and all of its Affiliates’ liability, taken together in the aggregate, arising out of or
related to this DPA, and all DPAs between Authorized Affiliates and Okta, whether in contract, tort or under any
other theory of liability, is subject to the ‘Limitation of Liability’ section of the Agreement, and any reference in
such section to the liability of a party means the aggregate liability of that party and all of its Affiliates under the
Agreement and all DPAs together. Okta's and its Affiliates’ total liability for all claims from the Customer and
all of its Authorized Affiliates arising out of or related to the Agreement and each DPA shall apply in the aggregate
for all claims under both the Agreement and all DPAs established under this Agreement, including by Customer
and all Authorized Affiliates, and shall not be understood to apply individually and severally to Customer and/or
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to any Authorized Affiliate that is a contractual party to any such DPA. Each reference to the DPA herein means
this DPA including its Appendices.
19. GDPR. Okta will Process Personal Data in accordance with the GDPR requirements directly applicable
to Okta's provision of the Service.
20. APEC Privacy Recognition for Processors. Okta has obtained APEC Privacy Recognition for
Processors (“PRP”) certification and shall Process Personal Data submitted to the Service as listed in Okta’s PRP
certification, which Okta makes available online at https://www.okta.com/trustandcompliance.
21. Data Protection Impact Assessment. Upon Customer’s request, Okta shall provide Customer with
reasonable cooperation and assistance needed to fulfil Customer’s obligation under the GDPR to carry out a data
protection impact assessment related to Customer’s use of the Service, to the extent Customer does not otherwise
have access to the relevant information, and to the extent such information is available to Okta. Okta shall provide
reasonable assistance to Customer in the cooperation or prior consultation with the Supervisory Authority in the
performance of its tasks relating to Section 21 of this DPA, to the extent required under the GDPR.
22. Standard Contractual Clauses. The Standard Contractual Clauses apply to:
(i) the legal entity that has executed the Standard Contractual Clauses as a data exporter and its Authorized
Affiliates and,
(ii) all Affiliates of Customer established within the European Economic Area, Switzerland and the United
Kingdom, which have signed Order Forms for the Service.
For the purpose of the Standard Contractual Clauses the aforementioned entities shall be deemed “data exporters.”
If necessary to fulfil its legal obligations, Customer may share a copy of the attached Standard Contractual Clauses
with Data Subjects.
23. Customer’s Processing Instructions. This DPA and the Agreement are Customer’s complete and final
instructions at the time of signature of the Agreement to Okta for the Processing of Personal Data. Any additional
or alternate instructions must be agreed upon separately. For the purposes of Clause 8.1 of the Standard
Contractual Clauses, the following is deemed an instruction by the Customer to process Personal Data:
(a) Processing in accordance with the Agreement and applicable Order Form(s);
(b) Processing initiated by Users in their use of the Service and
(c) Processing to comply with other reasonable instructions provided by Customer (e.g., via email) where such
instructions are consistent with the terms of the Agreement.
24. Audits. The parties agree that the audits described in Clause 8.9 of the Standard Contractual Clauses shall
be carried out in accordance with the following specifications: following Customer’s written request, and subject
to the confidentiality obligations set forth in the Agreement, Okta shall make available to Customer information
regarding the Okta Group’s compliance with the obligations set forth in this DPA in the form of the third-party
certifications and audits set forth in the Trust & Compliance Documentation, to the extent that Okta makes them
generally available to its customers. Customer may contact Okta in accordance with the “Notices” Section of the
Agreement to request an on-site audit of the procedures relevant to the protection of Personal Data. Customer
shall reimburse Okta for any time expended for any such on-site audit at the Okta Group’s then-current
professional services rates, which shall be made available to Customer upon request. Before the commencement
of any such on-site audit, Customer and Okta shall mutually agree upon the scope, timing, and duration of the
audit in addition to the reimbursement rate for which Customer shall be responsible. All reimbursement rates shall
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be reasonable, taking into account the resources expended by Okta. Customer shall promptly notify Okta and
provide information about any actual or suspected non-compliance discovered during an audit. The provision in
this section shall by no means derogate from or materially alter the provisions on audits as specified in the
Standard Contractual Clauses.
25. Data Deletion. The parties agree that the certification of deletion of Personal Data that is described in
Clauses 8.5 and 16(d) of the Standard Contractual Clauses shall be provided by Okta to Customer only upon
Customer’s request.
26. Language. The governing language of this DPA is English. Any Japanese language version of this DPA
is for reference purposes only. If there is any conflict between the English and Japanese version, the English
version shall prevail.
27. Order of Precedence. This DPA is incorporated into and forms part of the Agreement and the Standard
Contractual Clauses are incorporated by reference to this DPA. For matters not addressed under this DPA, the
terms of the Agreement apply. With respect to the rights and obligation of the parties vis-à-vis each other, in the
event of a conflict between the terms of the Agreement and this DPA, the terms of this DPA will control. In the
event of a conflict between the terms of the DPA and the Standard Contractual Clauses, the Standard Contractual
Clauses will prevail.
Agreed by Customer: Agreed by Okta, Inc.:
Signature: \si1\ ___________________________
Signature: \ si2\
By: \na1\ ________________________________ By: Jon Runyan
Title: \ti1\ ________________________________ Title: General Counsel
Date: \ds1\ _______________________________ Date: \ds2\
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ANNEXES TO THE STANDARD CONTRACTUAL CLAUSES (IF APPLICABLE)
ANNEX I
A. LIST OF PARTIES
Data exporter(s):
Name: The entity named as “Customer” in the DPA
Address: The address for Customer associated with its Okta account or as otherwise specified in the DPA or the
Agreement.
Contact person’s name, position and contact details: The address for Customer associated with its Okta account
or as otherwise specified in the Addendum or the Agreement
Activities relevant to the data transferred under these Clauses: Processing of Personal Data, where such data is
Customer Data, for the performance of the identity and access management cloud services upon the instruction
of the data exporter in accordance with the terms of the Agreement and the Data Processing Addendum.
Signature and date: By executing the DPA, the data exporter will be deemed to have signed this Annex I.
Role: Controller and/or processor
Data importer(s):
Name: Okta, Inc.
Address: 100 First Street, San Francisco, California 94105, USA
Contact person’s name, position and contact details: Timothy McIntyre, Data Protection Officer,
privacy@okta.com
Activities relevant to the data transferred under these Clauses: Processing of Personal Data, where such data is
Customer Data, for the performance of the identity and access management cloud services upon the instruction
of the data exporter in accordance with the terms of the Agreement and the Data Processing Addendum.
Signature and date: Timothy McIntyre (July 19, 2021)
Role: Processor on behalf of Customer
B. DESCRIPTION OF TRANSFER
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Categories of data subjects whose personal data is transferred
Data exporter may submit Personal Data to the Service, the extent of which is determined and controlled by the
data exporter in its sole discretion, and which may include, but is not limited to Personal Data relating to the
following categories of data subjects:
● Customers, business partners, and vendors of the data exporter (who are natural persons)
● Employees or contact persons of data exporter customers, business partners, and vendor
● Employees, agents, advisors, contractors, or any user authorized by the data exporter to use the Service
(who are natural persons)
Categories of personal data transferred
Data exporter may submit Personal Data to the Service, the extent of which is determined and controlled by the
data exporter in its sole discretion, and which may include, but is not limited to the following categories of
personal data:
● First and last name
● Business contact information (company, email, phone, physical business address)
● Personal contact information (email, cell phone)
● Title
● Position
● Employer
● ID data
● Professional life data
● Personal life data (in the form of security questions and answers)
● Connection data
● Localization data
Sensitive data transferred (if applicable) and applied restrictions or safeguards that fully take into consideration
the nature of the data and the risks involved, such as for instance strict purpose limitation, access restrictions
(including access only for staff having followed specialised training), keeping a record of access to the data,
restrictions for onward transfers or additional security measures.
Data exporter may submit special categories of data to the Service, the extent of which is determined and
controlled by the data exporter in its sole discretion, and which may include Personal Data concerning health
information. If applicable, data exporter agrees that it has reviewed and assessed the restrictions and safeguards
applied to the special categories of Personal Data, including the measures described in the Trust & Compliance
Documentation (as defined by this DPA) and Documentation (as defined in the Agreement), and has determined
that such restrictions and safeguards are sufficient.
The frequency of the transfer (e.g. whether the data is transferred on a one-off or continuous basis)
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Subject to Customer’s use of the Service, Personal Data will be transferred on a continuous basis during the term
of the Agreement.
Nature of the processing
Identity and access management and related services pursuant to the Agreement.
Purpose(s) of the data transfer and further processing
The objective of Processing of Personal Data by the data importer is the performance of the Service pursuant to
the Agreement and as instructed by data exporter in its use of the Service.
The period for which the personal data will be retained, or, if that is not possible, the criteria used to determine
that period
Data exporter may retain Personal Data in the Service for the duration of the Agreement. Personal Data within
the Service post-termination of the Agreement will be retained and deleted in accordance with the Documentation.
For transfers to (sub-) processors, also specify subject matter, nature and duration of the processing
Sub-processors may only Process Personal Data as necessary for the performance of the Service pursuant to the
Agreement and for the duration of the Agreement. Sub-processor information are made available on Okta’s
‘Agreements’ webpage (accessible via www.okta.com/agreements under the “Trust & Compliance
Documentation” link).
C. COMPETENT SUPERVISORY AUTHORITY
Identify the competent supervisory authority/ies in accordance with Clause 13
Where the data exporter is established in an EU Member State: The supervisory authority with responsibility for
ensuring compliance by the data exporter with Regulation (EU) 2016/679 as regards the data transfer shall act as
competent supervisory authority.
Where the data exporter is not established in an EU Member State, but falls within the territorial scope of
application of Regulation (EU) 2016/679 in accordance with its Article 3(2) and has appointed a representative
pursuant to Article 27(1) of Regulation (EU) 2016/679: The supervisory authority of the Member State in which
the representative within the meaning of Article 27(1) of Regulation (EU) 2016/679 is established shall act as
competent supervisory authority.
Where the data exporter is not established in an EU Member State, but falls within the territorial scope of
application of Regulation (EU) 2016/679 in accordance with its Article 3(2) without however having to appoint
a representative pursuant to Article 27(2) of Regulation (EU) 2016/679: The supervisory authority of one of the
Member States in which the data subjects whose personal data is transferred under these Clauses in relation to the
offering of goods or services to them, or whose behaviour is monitored, are located shall act as competent
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supervisory authority.
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ANNEX II
TECHNICAL AND ORGANISATIONAL MEASURES INCLUDING TECHNICAL AND
ORGANISATIONAL MEASURES TO ENSURE THE SECURITY OF THE DATA
Description of the technical and organisational measures implemented by the data importer(s) (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.
Okta maintains administrative, physical and technical safeguards for protection of the security, confidentiality
and integrity of Customer Data, including Personal Data, as set forth in the Trust & Compliance Documentation
(accessible via https://www.okta.com/trustandcompliance/). Okta regularly monitors compliance with these
safeguards. Okta will not materially decrease the overall security of the Service during a subscription term. Okta’s
Service is designed to permit data exporter to manage Data Subject Requests without assistance from Okta. If
data exporter cannot complete its obligations pursuant to a Data Subject Request without assistance from Okta,
then, and as set forth in Section 6 of the DPA, factoring into account the nature of the Processing, Okta shall assist
data exporter by appropriate organizational and technical measures, insofar as this is possible, for the fulfilment
of data exporter’s obligation to respond to a Data Subject Request.
For transfers to (sub-) processors, also describe the specific technical and organisational 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
Okta conducts reasonable due diligence and security assessments of Sub-processors, and enters into agreements
with Sub-processors that contain provisions similar to or more stringent than those provided for in the Security &
Privacy Documentation within Trust & Compliance Documentation. Okta will work directly with Sub-
processors, as necessary, to provide assistance to data exporter.
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ANNEX III
DATA TRANSFERS FROM THE UNITED KINGDOM AND SWITZERLAND
In case of any transfers of Personal Data from the United Kingdom and/or transfers of Personal Data from
Switzerland subject exclusively to the Data Protection Laws and Regulations of Switzerland (“Swiss Data
Protection Laws”), the following provisions apply:
1. General and specific references in the Standard Contractual Clauses to GDPR, or EU or Member State
Law, shall have the same meaning as the equivalent reference in the Data Protection Laws and Regulations
of the United Kingdom (“UK Data Protection Laws”) or Swiss Data Protection Laws, as applicable.
2. In respect of data transfers governed by Swiss Data Protection Laws, the Standard Contractual Clauses
also apply to the transfer of information relating to an identified or identifiable legal entity where such
information is protected similarly as Personal Data under Swiss Data Protection Laws until such laws are
amended to no longer apply to a legal entity.
3. Where the data exporter is established in the United Kingdom or falls within the territorial scope of
application of UK Data Protection Laws and Regulations, the Information Commissioner's Office shall
act as the competent supervisory authority. Where the data exporter is established in Switzerland or falls
within the territorial scope of application of Swiss Data Protection Laws and Regulations, the Swiss
Federal Data Protection and Information Commissioner shall act as competent supervisory authority
insofar as the relevant data transfer is governed by Swiss Data Protection Laws and Regulations.
4. Where the Agreement designates the United Kingdom as having exclusive jurisdiction, the United
Kingdom shall have exclusive jurisdiction to resolve any dispute arising from the Standard Contractual
Clauses. For Data Subjects habitually resident in Switzerland, the courts of Switzerland are an alternative
place of jurisdiction in respect of disputes.
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