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Scripts and page chrome removed; this is what change detection compares.
Data Processing Agreement Terms of Service Privacy and Cookie Policy Publisher Terms of Service Data Processing Agreement Last updated: 2026/09/21 This Data Processing Agreement (the “DPA”) forms part of the Agreement between NOW4REAL S.R.L. (“N4R”) and the Publisher. It applies solely to the processing of personal data carried out by N4R on behalf of the Publisher in connection with each Website for which WL Mode is or has been activated, for as long as N4R processes such personal data. Capitalized terms not otherwise defined in this DPA have the meanings given to them in the Publisher Terms of Service. For purposes of the Standard Contractual Clauses set out below, the Publisher is the controller and N4R is the processor. This DPA becomes binding when, in connection with the first activation of WL Mode for any Website managed through the Publisher account, the Publisher electronically accepts it through the Dashboard in accordance with Article 18.6 of the Publisher Terms of Service. Once accepted, this DPA automatically applies to every Website managed through the same Publisher account whenever WL Mode is activated for that Website, without requiring separate acceptance for each Website. The Standard Contractual Clauses set out below are those adopted by Commission Implementing Decision (EU) 2021/915 of June 4, 2021. The Clauses, as completed by the Annexes, form an integral part of this DPA. STANDARD CONTRACTUAL CLAUSES SECTION I Clause 1 Purpose and scope (a) The purpose of these Standard Contractual Clauses (the Clauses) is to ensure compliance with Article 28(3) and (4) of 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. (b) The controllers and processors listed in Annex I have agreed to these Clauses in order to ensure compliance with Article 28(3) and (4) of Regulation (EU) 2016/679. (c) These Clauses apply to the processing of personal data as specified in Annex II. (d) Annexes I to IV are an integral part of the Clauses. (e) These Clauses are without prejudice to obligations to which the controller is subject by virtue of Regulation (EU) 2016/679. (f) These Clauses do not by themselves ensure compliance with obligations related to international transfers in accordance with Chapter V of Regulation (EU) 2016/679. Clause 2 Invariability of the Clauses (a) The Parties undertake not to modify the Clauses, except for adding information to the Annexes or updating information in them. (b) This does not prevent the Parties from including the standard contractual clauses laid down in these Clauses in a broader contract, or from adding other clauses or additional safeguards provided that they do not directly or indirectly contradict the Clauses or detract from the fundamental rights or freedoms of data subjects. Clause 3 Interpretation (a) Where these Clauses use the terms defined in Regulation (EU) 2016/679, those terms shall have the same meaning as in that Regulation. (b) These Clauses shall be read and interpreted in the light of the provisions of Regulation (EU) 2016/679. (c) These Clauses shall not be interpreted in a way that runs counter to the rights and obligations provided for in Regulation (EU) 2016/679 or in a way that prejudices the fundamental rights or freedoms of the data subjects. Clause 4 Hierarchy In the event of a contradiction between these Clauses and the provisions of related agreements between the Parties existing at the time when these Clauses are agreed or entered into thereafter, these Clauses shall prevail. SECTION II – OBLIGATIONS OF THE PARTIES Clause 6 Description of processing(s) The details of the processing operations, in particular the categories of personal data and the purposes of processing for which the personal data is processed on behalf of the controller, are specified in Annex II. Clause7 Obligations of the Parties 7.1. Instructions (a) The processor shall process personal data only on documented instructions from the controller, unless required to do so by Union or Member State law to which the processor is subject. In this case, the processor shall inform the controller of that legal requirement before processing, unless the law prohibits this on important grounds of public interest. Subsequent instructions may also be given by the controller throughout the duration of the processing of personal data. These instructions shall always be documented. (b) The processor shall immediately inform the controller if, in the processor’s opinion, instructions given by the controller infringe Regulation (EU) 2016/679 or the applicable Union or Member State data protection provisions. 7.2. Purpose limitation The processor shall process the personal data only for the specific purpose(s) of the processing, as set out in Annex II, unless it receives further instructions from the controller. 7.3. Duration of the processing of personal data Processing by the processor shall only take place for the duration specified in Annex II. 7.4. Security of processing (a) The processor shall at least implement the technical and organisational measures specified in Annex III to ensure the security of the personal data. This includes protecting the data against a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access to the data (personal data breach). In assessing the appropriate level of security, the Parties shall take due account of the state of the art, the costs of implementation, the nature, scope, context and purposes of processing and the risks involved for the data subjects. (b) The processor shall grant access to the personal data undergoing processing to members of its personnel only to the extent strictly necessary for implementing, managing and monitoring of the contract. The processor shall ensure that persons authorised to process the personal data received have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality. 7.5. Sensitive data If the processing involves personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data or biometric data for the purpose of uniquely identifying a natural person, data concerning health or a person’s sex life or sexual orientation, or data relating to criminal convictions and offences (“sensitive data”), the processor shall apply specific restrictions and/or additional safeguards. 7.6 Documentation and compliance (a) The Parties shall be able to demonstrate compliance with these Clauses. (b) The processor shall deal promptly and adequately with inquiries from the controller about the processing of data in accordance with these Clauses. (c) The processor shall make available to the controller all information necessary to demonstrate compliance with the obligations that are set out in these Clauses and stem directly from Regulation (EU) 2016/679. At the controller’s request, the processor shall also permit and contribute to audits of the processing activities covered by these Clauses, at reasonable intervals or if there are indications of non-compliance. In deciding on a review or an audit, the controller may take into account relevant certifications held by the processor. (d) The controller may choose to conduct the audit by itself or mandate an independent auditor. Audits may also include inspections at the premises or physical facilities of the processor and shall, where appropriate, be carried out with reasonable notice. (e) The Parties shall make the information referred to in this Clause, including the results of any audits, available to the competent supervisory authority/ies on request. 7.7. Use of sub-processors (a) GENERAL WRITTEN AUTHORISATION: The processor has the controller’s general authorisation for the engagement of sub-processors from an agreed list. The processor shall specifically inform in writing the controller of any intended changes of that list through the addition or replacement of sub-processors at least two weeks in advance, thereby giving the controller sufficient time to be able to object to such changes prior to the engagement of the concerned sub-processor(s). The processor shall provide the controller with the information necessary to enable the controller to exercise the right to object. (b) Where the processor engages a sub-processor for carrying out specific processing activities (on behalf of the controller), it shall do so by way of a contract which imposes on the sub-processor, in substance, the same data protection obligations as the ones imposed on the data processor in accordance with these Clauses. The processor shall ensure that the sub-processor complies with the obligations to which the processor is subject pursuant to these Clauses and to Regulation (EU) 2016/679. (c) At the controller’s request, the processor shall provide a copy of such a sub-processor agreement and any subsequent amendments to the controller. To the extent necessary to protect business secret or other confidential information, including personal data, the processor may redact the text of the agreement prior to sharing the copy. (d) The processor shall remain fully responsible to the controller for the performance of the sub-processor’s obligations in accordance with its contract with the processor. The processor shall notify the controller of any failure by the sub-processor to fulfil its contractual obligations. (e) The processor shall agree a third party beneficiary clause with the sub-processor whereby – in the event the processor has factually disappeared, ceased to exist in law or has become insolvent – the controller shall have the right to terminate the sub-processor contract and to instruct the sub-processor to erase or return the personal data. 7.8. International transfers (a) Any transfer of data to a third country or an international organisation by the processor shall be done only on the basis of documented instructions from the controller or in order to fulfil a specific requirement under Union or Member State law to which the processor is subject and shall take place in compliance with Chapter V of Regulation (EU) 2016/679. (b) The controller agrees that where the processor engages a sub-processor in accordance with Clause 7.7. for carrying out specific processing activities (on behalf of the controller) and those processing activities involve a transfer of personal data within the meaning of Chapter V of Regulation (EU) 2016/679, the processor and the sub-processor can ensure compliance with Chapter V of Regulation (EU) 2016/679 by using standard contractual clauses adopted by the Commission in accordance with of Article 46(2) of Regulation (EU) 2016/679, provided the conditions for the use of those standard contractual clauses are met. Clause 8 Assistance to the controller (a) The processor shall promptly notify the controller of any request it has received from the data subject. It shall not respond to the request itself, unless authorised to do so by the controller. (b) The processor shall assist the controller in fulfilling its obligations to respond to data subjects’ requests to exercise their rights, taking into account the nature of the processing. In fulfilling its obligations in accordance with (a) and (b), the processor shall comply with the controller’s instructions (c) In addition to the processor’s obligation to assist the controller pursuant to Clause 8(b), the processor shall furthermore assist the controller in ensuring compliance with the following obligations, taking into account the nature of the data processing and the information available to the processor: (1) the obligation to carry out an assessment of the impact of the envisaged processing operations on the protection of personal data (a ‘data protection impact assessment’) where a type of processing is likely to result in a high risk to the rights and freedoms of natural persons; (2) the obligation to consult the competent supervisory authority/ies prior to processing where a data protection impact assessment indicates that the processing would result in a high risk in the absence of measures taken by the controller to mitigate the risk; (3) the obligation to ensure that personal data is accurate and up to date, by informing the controller without delay if the processor becomes aware that the personal data it is processing is inaccurate or has become outdated; (4) the obligations in Article 32 Regulation (EU) 2016/679. (d) The Parties shall set out in Annex III the appropriate technical and organisational measures by which the processor is required to assist the controller in the application of this Clause as well as the scope and the extent of the assistance required. Clause 9 Notification of personal data breach In the event of a personal data breach, the processor shall cooperate with and assist the controller for the controller to comply with its obligations under Articles 33 and 34 Regulation (EU) 2016/679, where applicable, taking into account the nature of processing and the information available to the processor. 9.1 Data breach concerning data processed by the controller In the event of a personal data breach concerning data processed by the controller, the processor shall assist the controller: (a) in notifying the personal data breach to the competent supervisory authority/ies, without undue delay after the controller has become aware of it (unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons); (b) in obtaining the following information which, pursuant to Article 33(3) Regulation (EU) 2016/679, shall be stated in the controller’s notification, and must at least include: (1) the nature of the personal data including where possible, the categories and approximate number of data subjects concerned and the categories and approximate number of personal data records concerned; (2) the likely consequences of the personal data breach; (3) the measures taken or proposed to be taken by the controller to address the personal data breach, including, where appropriate, measures to mitigate its possible adverse effects. Where, and insofar as, it is not possible to provide all this information at the same time, the initial notification shall contain the information then available and further information shall, as it becomes available, subsequently be provided without undue delay. (c) in complying, pursuant to Article 34 Regulation (EU) 2016/679, with the obligation to communicate without undue delay the personal data breach to the data subject, when the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons. 9.2 Data breach concerning data processed by the processor In the event of a personal data breach concerning data processed by the processor, the processor shall notify the controller without undue delay after the processor having become aware of the breach. Such notification shall contain, at least: (a) a description of the nature of the breach (including, where possible, the categories and approximate number of data subjects and data records concerned); (b) the details of a contact point where more information concerning the personal data breach can be obtained; (c) its likely consequences and the measures taken or proposed to be taken to address the breach, including to mitigate its possible adverse effects. Where, and insofar as, it is not possible to provide all this information at the same time, the initial notification shall contain the information then available and further information shall, as it becomes available, subsequently be provided without undue delay. The Parties shall set out in Annex III all other elements to be provided by the processor when assisting the controller in the compliance with the controller’s obligations under Articles 33 and 34 of Regulation (EU) 2016/679. SECTION III – FINAL PROVISIONS Clause 10 Non-compliance with the Clauses and termination (a) Without prejudice to any provisions of Regulation (EU) 2016/679, in the event that the processor is in breach of its obligations under these Clauses, the controller may instruct the processor to suspend the processing of personal data until the latter complies with these Clauses or the contract is terminated. The processor shall promptly inform the controller in case it is unable to comply with these Clauses, for whatever reason. (b) The controller shall be entitled to terminate the contract insofar as it concerns processing of personal data in accordance with these Clauses if: (1) the processing of personal data by the processor has been suspended by the controller pursuant to point (a) and if compliance with these Clauses is not restored within a reasonable time and in any event within one month following suspension; (2) the processor is in substantial or persistent breach of these Clauses or its obligations under Regulation (EU) 2016/679; (3) the processor fails to comply with a binding decision of a competent court or the competent supervisory authority/ies regarding its obligations pursuant to these Clauses or to Regulation (EU) 2016/679. (c) The processor shall be entitled to terminate the contract insofar as it concerns processing of personal data under these Clauses where, after having informed the controller that its instructions infringe applicable legal requirements in accordance with Clause 7.1 (b), the controller insists on compliance with the instructions. (d) Following termination of the contract, the processor shall, at the choice of the controller, delete all personal data processed on behalf of the controller and certify to the controller that it has done so, or, return all the personal data to the controller and delete existing copies unless Union or Member State law requires storage of the personal data. Until the data is deleted or returned, the processor shall continue to ensure compliance with these Clauses. SUPPLEMENTARY PROVISION CONCERNING SUB-PROCESSORS For purposes of Clause 7.7(a), the agreed list of sub-processors is set out in Annex IV. Notice of any intended addition or replacement shall be sent to the email address associated with the Publisher account. If the Controller objects on reasonable data-protection grounds within the notice period, the Parties shall work in good faith to find a reasonable solution. If no such solution is available, either Party may terminate the affected processing before the new sub-processor is engaged. SUPPLEMENTARY PROVISION CONCERNING RESTRICTED RETENTION The Clauses apply only to processing carried out by N4R on behalf of the Controller. Following termination of the relevant processing, deactivation of WL Mode or a documented deletion instruction, N4R will make the affected personal data unavailable to End Users and the Controller and will return or delete the personal data processed on behalf of the Controller in accordance with Clause 10(d). To the limited extent that N4R retains a restricted copy solely for compliance with applicable law or for the establishment, exercise or defense of legal claims, N4R acts as an independent controller in respect of that retention. The retained data will be segregated from the systems used to provide the Services, accessible only to specifically authorized personnel, used solely for those purposes and deleted within a maximum of six months, unless Union or Member State law requires a longer retention period. N4R will make the information concerning this limited processing available to the Controller, and the Controller shall include appropriate information about it in the privacy notice provided to the affected End Users. SUPPLEMENTARY PROVISION CONCERNING UPDATES TO THE DPA AND ANNEXES Subject to Clause 2, N4R may update the Annexes and the supplementary provisions of this DPA to keep them accurate and current in light of changes to the Services, processing operations, security measures, applicable law or information concerning the Parties. An update that is administrative or clarifying, reflects a change requested or enabled by the Controller, adds or strengthens safeguards, or does not materially and adversely affect the Controller’s rights or obligations or the protection of personal data may take effect when the revised DPA is published, without individual notice. For any other material update, N4R shall notify the Controller at the email address associated with the Publisher account at least fourteen days before the update takes effect. The Controller may object within that period on reasonable data-protection grounds. The Parties shall work in good faith to find a reasonable solution. If no such solution is available, either Party may terminate the affected processing before the update takes effect. If the Controller does not object within the notice period, the updated DPA shall become binding on its effective date without further express acceptance. An update required by applicable law or reasonably necessary to address an urgent security risk may take effect on shorter notice, in which case N4R shall notify the Controller as soon as reasonably practicable. Changes to Annex IV remain governed by Clause 7.7(a) and the Supplementary Provision Concerning Sub-processors. Nothing in this provision permits N4R to modify the Clauses except as allowed by Clause 2, materially reduce the overall level of protection of personal data, or process personal data for new purposes or beyond the Controller’s documented instructions. ANNEX I – List of Parties Controller(s): Name: The legal or natural person identified as the Publisher in the billing information associated with the Publisher account through which this DPA is accepted. Address: The billing address associated with that Publisher account at the time of acceptance. Contact person’s name, position and contact details: The account holder or other contact person identified in the Publisher account, at the email address associated with that account. Where applicable, the Controller may provide the contact details of its data protection officer by writing to [email protected]. Signature and accession date: The Controller concludes this DPA electronically by accepting it through the Dashboard. The corresponding date and time recorded by N4R constitute the accession date. Processor(s): Name: NOW4REAL S.R.L. Address: Viale Andrea Doria 7, 20124 Milan, Italy Contact person’s name, position and contact details: Alessandro Alinone, Chief Executive Officer, [email protected] Signature and accession date: N4R concludes this DPA electronically when the Controller accepts it through the Dashboard. The corresponding date and time recorded by N4R constitute N4R’s accession date. ANNEX II – Description of the Processing Categories of data subjects whose personal data is processed The personal data processed may relate to: End Users who access or use the Services on a Website configured in WL Mode, including End Users who use the Services without registration and minors where the Controller permits their use; moderators and other persons authorized by the Controller to administer or moderate the Services; and other individuals whose personal data is included in Content submitted through the Services. Categories of personal data processed Depending on the Access Procedure and features selected by the Controller, the following categories of personal data may be processed: identity, profile and access data, including internal identifiers, identifiers and authentication claims provided by the Controller, display names or nicknames, profile images, email addresses and email-derived hashes, email authentication records, permissions and session identifiers; Content and interaction data, including chat messages, replies, edits and edit history, reactions, reports and reporting reasons, GIF search terms and GIFs selected or viewed; moderation and administration data, including moderation actions, rejection decisions and reasons, applicable moderation policies and the identity of moderators, reporting End Users and reported End Users; contextual data, including the relevant Website, page address or title, chat context or custom identifier, timestamps, message identifiers, visibility settings and other configurations selected by the Controller; technical, connection and security-assessment data, including IP addresses, TCP source ports, connection and session timestamps, browser or device information, ordinary server-log data and, where Google reCAPTCHA is used, interaction signals, cookie or similar identifiers, reCAPTCHA tokens and verification or risk results; presence and approximate location data processed in real time, including the country inferred from an IP address, and the resulting aggregated counters; data processed or generated when AI-based moderation or Automated Agents are enabled, including relevant recent messages, pseudonymous identifiers, moderation outputs and messages or responses generated by Automated Agents; and any other personal data voluntarily included by an End User or the Controller in Content or instructions submitted through the Services. Sensitive data processed and safeguards applied The Services do not require End Users to provide special categories of personal data referred to in Article 9 GDPR or personal data relating to criminal convictions and offenses referred to in Article 10 GDPR. However, because Content is unstructured, End Users or the Controller may include such data in Content submitted through the Services. The Controller is responsible for determining whether such processing is appropriate and lawful and for providing N4R with any necessary documented instructions. N4R processes such data only as necessary to provide, moderate, secure and support the Services in accordance with those instructions. The applicable safeguards include purpose limitation, access restrictions, confidentiality obligations, encryption during transmission, logging, Controller-configured access and visibility controls, retention controls, the use of pseudonymous identifiers when data is submitted for AI-based moderation, the use of a randomly generated value that contains no N4R or Controller user identifier in KLIPY’s API user-ID field, and the technical and organizational measures described in Annex III. Nature of the processing The processing may include receiving, collecting, recording, organizing, structuring, storing, retrieving, consulting, displaying, transmitting, making available, matching, moderating, filtering, analyzing, aggregating, restricting, deleting and otherwise processing personal data as necessary to provide the Services. Where enabled by the Controller, the processing may also include automated analysis for moderation purposes and the transmission of relevant data to an HTTPS endpoint selected and controlled by the Controller for the operation of Automated Agents. Purposes for which the personal data is processed on behalf of the Controller Personal data is processed on behalf of the Controller solely to: provide and operate the Services on Websites configured in WL Mode, including chat, presence, counters, Access Procedures, security verification through reCAPTCHA, profile-picture retrieval and display through Gravatar, moderation tools, GIF search and content delivery, notifications, transcripts, reports and Dashboard functionality; implement the Controller’s configurations and documented instructions concerning access, visibility, retention, moderation and Automated Agents; enable the Controller and its authorized moderators to administer and moderate the Services; provide technical support, troubleshoot technical issues, maintain security and prevent misuse of the Services; perform AI-based moderation where enabled by the Controller; generate aggregate statistics that are irreversibly anonymized; and comply with applicable legal requirements in accordance with the Clauses. Duration of the processing N4R processes personal data on behalf of the Controller for as long as WL Mode remains active for the relevant Website and for the retention period selected or instructed by the Controller. The Controller may configure the period during which Content remains available to End Users and may instruct N4R to retain Content for an indefinite period. Content, its edit history, reactions, reports, moderation records and the technical connection data associated with a message follow the retention period applicable to that message, unless otherwise instructed by the Controller. Ordinary server logs are retained for a maximum of six months. A separate security record containing the IP address, TCP source port and date and time of a connection may be retained for a maximum of twelve months. Following termination of the relevant processing, deactivation of WL Mode or a documented deletion instruction, the affected data is made unavailable to End Users and the Controller and is returned or deleted in accordance with Clause 10(d). Any subsequent restricted retention carried out by N4R as an independent controller is governed by the Supplementary Provision Concerning Restricted Retention and is not processing on behalf of the Controller under this Annex II. Use of Gravatar Where the Controller enables an email-based Access Procedure and an End User chooses to use Gravatar, the Controller instructs N4R to derive a hash from the End User’s email address and use it to retrieve and display the associated public profile picture. Displaying the picture causes the viewer’s browser to connect directly to Gravatar and transmit the image address containing the hash and ordinary technical connection data. Automattic acts as an independent controller for the data it receives through Gravatar. The Controller remains responsible for providing the information required by applicable data protection law. Use of KLIPY Where the Controller makes GIF functionality available on a Website in WL Mode, the Controller instructs N4R to enable access to content supplied by Kikliko, Inc. (“KLIPY”). When an End User opens the GIF picker or when a GIF supplied by KLIPY is displayed in a Chat, the End User’s browser connects directly to KLIPY through an iframe operated by N4R. KLIPY may receive the End User’s IP address and related browser and HTTP request data, the identity of N4R as the third-party integration, search terms, GIFs viewed or selected, timestamps and diagnostic or usage information. Because the request originates from an N4R-hosted iframe, its HTTP Referer header identifies only the iframe origin, https://cdn.now4real.com/, and does not disclose the identity or address of the Website to KLIPY. KLIPY does not set or read cookies through this integration. N4R supplies a randomly generated value in the API user-ID field; the value is generated independently of, and does not contain, any N4R or Controller user identifier. N4R does not use KLIPY’s Ads/Revenue API and does not display KLIPY advertising through the integration. KLIPY independently determines the purposes and means of the processing it performs with data collected from the End User’s browser and acts as an independent controller for that processing. KLIPY is not appointed as a sub-processor under this DPA and is not listed in Annex IV. Its processing, including processing in the United States, is described in the KLIPY Privacy Policy at https://klipy.com/support/privacy-policy. The Controller remains responsible for deciding whether to make the functionality available, establishing an appropriate legal basis and providing the information required by applicable data protection law. N4R does not transmit Controller or End User personal data stored in its systems to KLIPY through the integration. Processing by sub-processors Sub-processors process only the personal data necessary to provide the respective infrastructure, hosting, content-delivery, email-delivery, AI-based moderation or other supporting services described in Annex IV. Their processing may include hosting, storage, transmission, delivery, technical support and, where applicable, automated analysis. It continues only for as long as the relevant sub-processor is engaged and the data remains necessary for the applicable processing activity, subject to the deletion or return obligations imposed by the relevant sub-processing agreement. Further details are provided in Annex IV. ANNEX III – Technical and Organizational Measures Including Technical and Organizational Measures to Ensure the Security of the Data N4R implements the following technical and organizational measures for the processing described in Annex II. These measures apply to the systems and processing operations under N4R’s control. Sub-processors are subject to the requirements set out in the Clauses and Annex IV. Security Governance and Personnel N4R assigns responsibility for information security to designated management and technical personnel. Persons authorized to process personal data are bound by confidentiality obligations and receive appropriate security and data-protection training. N4R maintains procedures covering access management, secure development, vulnerability management, incident response, operational recovery, retention and deletion. N4R personnel and contractors are not permitted to access production personal data from outside the EEA. Infrastructure, Network Security and Data Segregation The Services are provided as software-as-a-service using an AWS account dedicated to N4R. Primary production databases, operational logs and backups stored directly by N4R are hosted in the AWS eu-west-1 Region in Ireland and are not replicated by N4R outside the EEA. Production systems are protected through virtual private networks, security groups, firewalls and network segmentation. Public access is limited to the endpoints and ports required to provide the Services. Administrative access is separately restricted. Data relating to different Controllers and Websites are logically segregated through application-level authorization and tenant controls. Identification, Authentication and Access Control Access to production systems is granted through individual accounts according to the principles of least privilege and need to know. Administrative and production access is protected by multi-factor authentication. Access rights are reviewed periodically and revoked promptly when no longer required. Root or emergency accounts are not used for ordinary operations and are protected by multi-factor authentication. Access to the Dashboard is limited to authorized Publisher accounts. Where the Access Procedure includes authentication, the applicable credentials, tokens or cryptographic assertions are validated before access is granted. Custom Authentication credentials and JWT secrets are handled through protected credential-management procedures. N4R uses Google reCAPTCHA during the email-based Access Procedure to detect and prevent automated activity, spam and abuse. reCAPTCHA is loaded only on the email-entry page when that Access Procedure is used. N4R does not include the End User’s email address, profile information or Content in the reCAPTCHA verification request and does not retain the reCAPTCHA token or result after completion of the relevant security check. Passwords are stored only in cryptographically hashed form. API keys, access and refresh tokens, signing secrets and other retrievable production credentials are stored in encrypted, access-controlled systems and are not embedded in publicly accessible code. Encryption and Pseudonymization Connections between End Users, Publishers and N4R systems are protected in transit using TLS. Publisher-configured Automated Agent endpoints must use HTTPS. Personal data stored in Amazon Aurora, EBS and S3, including backups, are encrypted at rest. Where AI-based moderation is enabled, N4R uses pseudonymous identifiers when transmitting message context to the relevant provider. Display names and direct End User account identifiers are not transmitted for that purpose. When an End User opens the GIF picker or when a GIF supplied by KLIPY is displayed in a Chat, the End User’s browser connects directly to KLIPY through an iframe operated by N4R. Because the request originates from an N4R-hosted iframe, its HTTP Referer header identifies only the iframe origin, https://cdn.now4real.com/, and does not disclose the identity or address of the Website to KLIPY. KLIPY does not set or read cookies through this integration. N4R supplies a randomly generated value in the API user-ID field; the value is generated independently of, and does not contain, any N4R or Controller user identifier. N4R does not use KLIPY’s Ads/Revenue API and does not display KLIPY advertising through the integration. Gravatar profile pictures are requested through an N4R-hosted iframe, so that the referrer identifies only the N4R iframe origin and does not disclose the identity or address of the relevant Website. N4R does not send the End User’s email address in clear text or the viewer’s N4R identifier. As currently implemented, the integration does not involve cookies. Endpoint and Software Security Devices authorized to access production systems use full-disk encryption, automatic screen locking and anti-malware protection. N4R applies security updates to operating systems, containers, application runtimes, dependencies and application software according to the associated risk, with critical security updates receiving priority. Only trusted system images, software and dependencies are used in production. Secure Development, Configuration and Change Management Application code and infrastructure configuration are maintained in version-controlled repositories. Changes are subject to appropriate review and controlled deployment procedures. N4R performs code review and dependency and vulnerability checks as part of its development and maintenance processes. Production credentials and secrets are separated from source code. System and network configurations follow secure defaults and are modified only by authorized personnel. Logging and Monitoring Relevant administrative access, system activity, security events and operational errors are logged and monitored using centralized logging and monitoring systems. Access to logs is restricted to authorized personnel, and logs are protected against unauthorized alteration or disclosure. Ordinary server logs are retained for no more than six months, as described in Annex II, unless a shorter period applies or further retention is required by applicable law. Availability, Backup and Recovery The production architecture uses availability and resilience measures that include multiple availability zones, load balancing, automated scaling and managed database services. Encrypted backups are created automatically. Their lifecycle follows the retention period applicable to the source data. N4R periodically tests its ability to restore data and resume the Services following a physical or technical incident. Security Testing and Vulnerability Management N4R periodically assesses the effectiveness of its technical and organizational measures. These activities include code review, dependency and vulnerability checking and risk-based security testing. Penetration testing is typically performed every six months. Identified vulnerabilities are evaluated and addressed according to their severity and the risk presented to the Services and personal data. Data Minimization and Data Quality N4R processes only the personal data and message context reasonably necessary to provide, secure, moderate and support the Services in accordance with the Controller’s instructions. Where automated moderation or Automated Agents require conversational context, only the recent messages and related information necessary for the relevant operation are used. N4R preserves the integrity and associated timestamps of data received through the Services. Available Service controls and documented Controller instructions may be used to correct, update or remove data where applicable. Retention, Deletion and Restricted Storage Automated processes enforce the retention periods described in Annex II or configured by the Controller. Personal data are deleted when the applicable retention period expires or in response to a valid Controller instruction, subject to the Clauses and the Supplementary Provision Concerning Restricted Retention. Where that Supplementary Provision applies, the retained data are removed from active Service systems and placed in a logically segregated archive. They are no longer accessible to End Users or the Controller, may be accessed only by specifically authorized N4R personnel for the purposes stated in that provision and are automatically deleted when the applicable restricted retention period expires. Incident Response N4R maintains a procedure for identifying, assessing, containing, documenting and remediating security incidents. Where a personal data breach affects data processed on behalf of the Controller, N4R will notify and assist the Controller without undue delay in accordance with the Clauses. The information supplied will include, to the extent available to N4R, the nature of the incident, the affected data and systems, the likely consequences and the measures taken or proposed to contain and remediate it. Physical Security N4R does not operate its own production data centers. Physical security for the cloud infrastructure is provided by AWS under its documented data-center security and compliance controls. Access to N4R devices and working environments is restricted to authorized persons, and devices capable of accessing production systems are protected as described above. Sub-processor Management Before engaging a sub-processor, N4R assesses the nature of the processing, the applicable data-protection safeguards and the relevant security information made available by that provider. N4R imposes contractual data-protection and security obligations consistent with Article 28 GDPR and the Clauses. Sub-processors are permitted to process personal data only as necessary to provide the services described in Annex IV and are subject to confidentiality, security, incident-notification and deletion or return obligations. Assistance to the Controller Taking into account the nature of the processing and the information available to N4R, N4R maintains procedures and technical capabilities to assist the Controller with: (a) responding to requests concerning data-subject rights; (b) investigating and documenting personal data breaches; (c) assessing the security of the processing; (d) conducting data-protection impact assessments and consultations with supervisory authorities where required; and (e) extracting, returning or deleting personal data in accordance with the Controller’s documented instructions and the Clauses. Such assistance may include identifying relevant records, applying access restrictions, providing available technical and security information and carrying out appropriate correction, deletion, export or preservation operations. ANNEX IV – Agreed List of Sub-processors For purposes of Clause 7.7(a), Option 2, the following is the agreed list of sub-processors. Each sub-processor is engaged only to the extent that the corresponding service or functionality is used in connection with a Website in WL Mode. Amazon Web Services EMEA SARL Address: 38 Avenue John F. Kennedy, L-1855 Luxembourg Contact person’s name, position and contact details: AWS Data Protection Officer, [email protected] Description of the processing: Provision of the cloud infrastructure supporting the Services, including computing, networking, managed databases, storage, encrypted backups, logging, monitoring, security and email delivery through Amazon SES. AWS may process the categories of personal data described in Annex II to the extent necessary to provide these services. N4R configures its primary production databases, operational logs and backups in the AWS eu-west-1 Region in Ireland. BunnyWay d.o.o. Address: Dunajska cesta 165, 1000 Ljubljana, Slovenia Contact person’s name, position and contact details: Privacy Team, [email protected] Description of the processing: Delivery of font files used by the Services through Bunny Fonts. The processing is limited to the transient handling of IP addresses and HTTP request data necessary to deliver the requested files. No Content, profile data or direct End User identifiers are sent by N4R to BunnyWay. Bunny Fonts operates under a zero-tracking and no-logging policy. Google Cloud Italy S.r.l. Address: Via Federico Confalonieri 4, 20124 Milan, Italy Contact person’s name, position and contact details: Google Cloud Data Protection Team, https://support.google.com/cloud/contact/dpo Description of the processing: Provision of bot-detection, risk-analysis and abuse-prevention services through Google reCAPTCHA during the email-based Access Procedure. Google may process IP addresses, browser, device and HTTP request data, cookie or similar identifiers, interaction signals, reCAPTCHA tokens and verification or risk results. N4R does not provide the End User’s email address, profile information or Content to Google for this purpose and does not retain reCAPTCHA tokens or results after completion of the relevant security check. Under the applicable service terms, the data are processed only to provide and protect reCAPTCHA and are not used for personalized advertising. Google may process the data in countries in which Google or its sub-processors maintain facilities, subject to the safeguards set out in the Google Cloud Data Processing Addendum. OpenAI Ireland Ltd. Address: 1st Floor, The Liffey Trust Centre, 117-126 Sheriff Street Upper, Dublin 1, D01 YC43, Ireland Contact person’s name, position and contact details: Data Protection Officer, [email protected] Description of the processing: Provision of AI-based moderation where enabled by the Controller. OpenAI receives and automatically analyzes recent chat messages, a pseudonym, the relevant page title and the moderation policy defined by the Controller. N4R does not send display names or direct End User account identifiers for this purpose. OpenAI returns a moderation decision and, where a message is rejected, the corresponding reason. API requests are configured with “store” set to false and are not used to train or improve OpenAI’s models. OpenAI may retain inputs and outputs in abuse-monitoring logs for up to 30 days, unless longer retention is required by law or is reasonably necessary to protect its services or third parties from harm. Volentio JSD Limited (jsDelivr) Address: Suite 2A1, Northside House, Mount Pleasant, Barnet, England, EN4 9EB, United Kingdom Contact person’s name, position and contact details: Legal and Privacy Team, [email protected] Description of the processing: Delivery through the jsDelivr global content-delivery network of public software libraries and static resources used by the Services. The technical data processed may include IP addresses, browser and user-agent information, referrer information, requested CDN URLs, timestamps and diagnostic information necessary for delivery, security and performance. No Content, profile data or direct End User account identifiers are sent by N4R to jsDelivr. Add Now4real to your site today Easy. Free. Instant. Let visitors chat, discover hot pages, and build instant communities—right on your website. 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