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Data processing addendum
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https://get.sendbird.com/rs/047-LOL-803/images/Sendbird-Customer-Data-Processing-Agreement%20Ver%204.3_Aug%2013%202026_%28GT%20REV%208.2026%29.pdf?version=0
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Scripts and page chrome removed; this is what change detection compares.

                     Sendbird Corporate Customer Data Processing Agreement
                                                  Effective as of August 13, 2026
                                                              Ver 4.3
    Sendbird, Inc. (“Sendbird” or “us” or “our”) serves enterprises, public sector entities and other organizations
    (“Customers”) and protects Customer Data in compliance with the terms of this Corporate Customer Data Processing
    Agreement (“DPA”). “Customer Data” means personal data relating to named or identifiable individuals that Customer’s
    authorized users upload to our servers in compliance with applicable law and our applicable service agreement or other
    commercial contract terms (“Contract”) when Customer’s use our remote access software-as-a-service offerings and
    related data processing services as described in our Instructions and Technical Specifications document as amended from
    time to time (“Services”).
    1.​      Control and Ownership. The subject matter, nature, purpose and duration of the processing, as well as the types of
    Customer Data collected and categories of data subjects, are described in Schedule 1 of this DPA. Customers own and
    control all Customer Data. Sendbird does not use Customer Data, except: (a) in the interest and on behalf of the Customer;
    (b) as necessary to provide, maintain, secure, support, and monitor the quality, security, and performance of the Services,
    or (c) as contemplated or directed by the Contract. Sendbird shall notify Customer in the event Sendbird makes a
    determination that it can no longer meet its obligations under applicable privacy law. Sendbird returns or deletes Customer
    Data at Customer’s request, as agreed in the Contract, or after the Contract expires or is terminated. Sendbird reserves all
    rights to the Services, Sendbird ‘s technology and Sendbird’s data, including any information that Sendbird discovers,
    creates or derives as it provides Services, except Customer Data. Customer understands that it is solely responsible for
    obtaining any needed consents or authorizations for Sendbird to process Customer Data. Customer will ensure that its
    instructions comply with applicable law, including any applicable privacy laws. Customer acknowledges that Sendbird is
    neither responsible for determining which laws or regulations are applicable to Customer’s business nor whether
    Sendbird’s provision of the Services meets or will meet the requirements of such laws or regulations. Customer will ensure
    that Sendbird’s processing of Customer Data, when done in accordance with Customer’s instructions, will not cause
    Sendbird to violate any applicable law or regulation, including applicable privacy laws.
    2.​     Security. Sendbird applies the technical, administrative and organizational data security measures as set forth in
    Schedule 2 of this DPA (collectively, “TOMS”). Sendbird may update and modify its TOMs from time to time, provided
    that Sendbird must not reduce the level of security provided thereunder, except with Customer’s consent or with 90 days
    prior written notice (or sooner if required to avoid or mitigate a security incident).
    3.​     Cooperation with Compliance Obligations. At Customer’s reasonable request and as required by applicable
    privacy law, Sendbird will (a) reasonably assist Customer with data access, deletion, portability and other requests, subject
    to compensation for any custom efforts required of Sendbird, (b) assist Customer in ensuring compliance with its
    obligations under applicable privacy law, including taking into account the nature of processing and the information
    available to the Sendbird and (c) enter into additional contractual agreements to meet specific requirements that are
    imposed by mandatory laws on Customer pertaining to Customer Data and that, due to their nature, can only be satisfied
    by Sendbird in its role as service provider or that Customer specifically explains and assigns to Sendbird in an addendum
    or amendment to the applicable Contract, subject to additional cost reimbursement or fees as appropriate. For the
    avoidance of doubt, Sendbird shall only assist and enable Customer to meet Customer’s obligations to satisfy data
    subjects' rights, but Sendbird shall not respond directly to data subjects, unless required by law to do so. Additionality,
    when requested to do so by Customer, Sendbird will promptly make available to Customer all information necessary to
    assist Customer with its obligations related to conducting a privacy impact assessment. If Customer can no longer legally
    use Sendbird’s products due to changes in law or technology, Sendbird shall allow Customer to terminate certain or all
    contracts and provide transition or migration assistance as reasonably required, subject to termination charges and fees as
    mutually agreed in good faith by the parties.
    4.​     Submit to Audits. Sendbird submits to reasonable data security and privacy compliance audits and shares audit
    report results with Customer. Sendbird also offers a customer audit program subject to reasonable precautions and
    safeguards for the data of other customers.
    5.​     Notify Breaches. Unless otherwise prohibited by applicable law, Sendbird notifies Customer of a Security Breach
    without undue delay after Sendbird confirms a Security Breach. “Security Breach” means a breach of Sendbird’s security
    leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Customer Data
    in Sendbird’s possession, custody or control. Security Breaches do not include unsuccessful attempts or activities that do
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    not compromise the security of Customer Data, including unsuccessful log-in attempts, pings, port scans, denial of service
    attacks, or other network attacks on firewalls or networked systems.

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    6.​      CCPA Obligations. Sendbird does not accept or disclose any Customer Data as consideration for any payments,
    services or other items of value. Sendbird does not sell or share any Customer Data, as the terms “sell” and “share” are
    defined in the California Consumer Privacy Act of 2018, as amended, including by the California Privacy Rights Act
    (“CCPA”). Sendbird processes Customer Data only for the business purposes specified in the written Contract. Sendbird
    does not retain, use, or disclose Customer Data (a) for cross‐context behavioral advertising, or (b) outside the direct
    business relationship with the Customer. Sendbird does not combine Customer Data with other data if and to the extent
    this would be inconsistent with limitations on service providers under the CCPA. To the extent Sendbird receives
    deidentified data from Customer or the Services under the Agreement allow for the deidentification of Customer Data,
    Sendbird represents and warrants to not reidentify, attempt to reidentify, or direct any other party to reidentify any data that
    has been deidentified, unless such services are contemplated under the Contract.
    7.​      Subprocessors. Customer hereby agrees and provides a general authorization that Sendbird may engage Sendbird’s
    affiliates or third parties as sub-processors to provide the Services. Sendbird will ensure that the sub-processors have
    entered into a written agreement that is no less protective than this DPA. Sendbird will be fully liable for the acts and
    omissions of any sub-processors to the same extent as if the acts or omissions were performed by Sendbird. Unless
    otherwise necessary to protect the security or integrity of Customer Data, in which Sendbird shall promptly provide prior
    notice, Sendbird shall provide Customer with thirty (30) days prior notice of any additional or replacement sub-processors
    via our administrative dashboard and our website at https://sendbird.com/sub-processors. After being notified, Customer
    must notify Sendbird in writing (email shall suffice) withing five (5) days of any reasonable objection it has to such
    sub-processors. In the event Customer provides a reasonable objection, Sendbird will use commercially reasonable efforts
    to make a change in processing under the Contract to avoid processing of Customer Data by such sub- processors. If
    Sendbird is unable to make available such change within a reasonable period of time, Customer may terminate the Services
    provided under the Contract in respect only to those services which cannot be provided by Sendbird without the use of the
    objected-to sub-processors, by providing written notice to Sendbird.
    8.​      Confidentiality. Without prejudice to any existing contractual arrangements between the parties, Sendbird will treat
    all Customer Data as confidential and it will inform all its employees, agents and any approved sub-processors engaged in
    processing the Customer Data of the confidential nature of the Customer Data. Sendbird will ensure that all such persons or
    parties have signed an appropriate confidentiality agreement, are otherwise bound to a duty of confidentiality, or are under
    an appropriate statutory obligation of confidentiality.
     9.​ International Data Transfers. If the Services involve the transfer of Customer Data from the European Economic Area,
    the United Kingdom, or Switzerland to Sendbird, such transfer will be undertaken pursuant to, as applicable, the European
    Union’s Standard Contractual Clauses, the United Kingdom’s International Data Transfer Addendum to the EU
    Commission Standard Contractual Clauses, and the EU Commission Standard Contractual Clauses as amended for use in
    connection with Customer Data from Switzerland (collectively, the “SCCs”). Notwithstanding the foregoing, any such
    transfers to Sendbird in the United States (“US Transfers”) will be made subject to Sendbird’s self-certification to the EU-
    U.S. and/or the Swiss-U.S. Data Privacy Framework (“DPF”), including, where applicable, the UK Extension of the DPF
    which is operated by the U.S. Department of Commerce. In the event that the DPF is invalidated or is otherwise determined
    by applicable regulatory authorities to no longer constitute a legal mechanism for such transfers, Sendbird will, at
    Customer’s request, enter into the applicable SCCs in connection with any such US transfers.

    10.​    Deletion of Customer Data. Sendbird shall return and/or delete Customer Data in accordance with the applicable
    provisions in the Contract.

    11.​    Liability. Each party’s liability with respect to its obligations under this DPA is set forth in the Contract.

    12.​    Integration. This DPA is binding on Sendbird if and to the extent it is expressly agreed or incorporated by reference
    in a duly signed Contract. This DPA shall not create third party beneficiary rights. Sendbird does not accept or submit to
    additional requirements relating to Customer Data, except as specifically and expressly agreed in writing with explicit
    reference to the Contract and this DPA. To the extent of applicable law, any claims brought under, or in connection with,
    this DPA, shall be subject to the exclusions and limitations of liability set forth in the Contract.

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    Schedule 1 – Details of Processing

    Subject Matter                       The context for the processing of Customer Data is
                                         Sendbird’s provision of the Services.

    Categories of Customer Data          Customer Personal Data contained in,
                                         communication content, traffic data, End-User
                                         data, and customer usage data. Communication
                                         content, which may include Personal Data or other
                                         personalized characteristics, depending on the
                                         communication content as determined by you as
                                         the Customer. Traffic data, which may include
                                         Customer Personal Data about the routing,
                                         duration or timing of a message, whether it relates
                                         to an individual or a company. End-User data, such
                                         as any identifier used in setting up and sending
                                         messages. Customer usage data, may contain data
                                         that can be linked to you as an individual included
                                         in statistical data and information related to your
                                         account and service activities, service related
                                         insights and analytic reports regarding
                                         communication sent and customer support.
                                         Sensitive data may, from time to time, be
                                         processed via the Services where you or your
                                         End-Users choose to include sensitive data within
                                         the communications that are transmitted using the
                                         Services. You are responsible for ensuring that
                                         suitable safeguards are in place prior to
                                         transmitting or processing, or prior to permitting
                                         your End-Users to transmit or process any
                                         sensitive data via the Services
     Categories of Data Subjects         Customer’s contact persons (natural persons) or
                                         employees, contractors or temporary workers
                                         (current, prospective, former) using the Services
                                         through the Customer’s account (“Users”);End-
                                         Users. Any individual (i) whose contact details are
                                         included in the Customer's contacts list(s); (ii)
                                         whose information is stored on or collected via the
                                         Services, or (ii) to whom Customer sends
                                         communications or otherwise engage or
                                         communicate with via the Services (collectively,
                                         “End-Users”). You as the Customer solely
                                         determine the categories of data subjects included
                                         in the communication sent through our Services.
     Nature and Purpose of Processing    For the nature and purposes required to provide the
                                         Services, as set forth in the Contract.
     Duration of Processing              Duration of performance of the Services.

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  Schedule 2 – Security Measures

      1.​ Service Infrastructure Management:
      ●​ Physical Security: Sendbird has a security program that manages visitors, office entrances, and information assets
         across geographically distributed offices. Sendbird takes advantage of AWS data centers for all production systems
         and Customer Data. Our infrastructure management is designed and built on AWS's security policies.
      ●​ Network Security: Sendbird has established procedural and technical standards for deploying network functions to
         production. These standards include baseline configurations for network components, network architecture, and
         approved protocols and ports. All network components are monitored to prevent malicious activities that might
         affect the company's infrastructure and to maintain compliance with technical standards. Using a virtual private
         network (VPN) and the trusted firewalls, Sendbird keeps the service environment safe and secure from external
         threats and vulnerabilities.
      ●​ Cloud Security: The Sendbird service is hosted on AWS which offers state-of-the-art physical protection for the
         servers and related infrastructure that comprise the service environment. AWS geographic regions and Auto Scaling
         allows Sendbird to build a highly resilient service for clients. It also allows Sendbird to manage the production
         servers so that they remain operational against the effects of unexpected events such as natural disasters and local
         outages.
      ●​ Monitoring: Sendbird's monitoring program focuses on detecting and reporting vulnerabilities in our service and
         products. All system changes and vulnerabilities are monitored and audited with AWS Cloudtrail and AWS
         GuardDuty. Based on inbound security reports, our engineers quickly analyze vulnerabilities, find the best solutions,
         and resolve issues.
      ●​ Audit Log: Sendbird only grants authorized employees access to Customer Data based on the principle of least
         privilege. They are required to use proprietary monitoring tools to detect intrusion attempts and other
         security-related alerts and to record audit logs for their activities. Audit logs are maintained for all operations and
         activities such as privileged user access and unauthorized access attempts of Customer Data.
      2.​ Access Security
      ●​ Authentication - MFA, OTP: Access to Customer Data is restricted to authorized employees. Sendbird applies multi-
         factor authentication (MFA) and controls for administrative access to its system. For secure authentication,
         employees are required to use a proprietary VPN solution with MFA when accessing the system. And upon a data
         owner's request and approval, temporary access to Customer Data is granted to only a limited group of employees by
         using a one-time password. All related activities are tracked by audit logs. Access to the company's system and
         Customer Data requires two-factor authentication according to the following criteria: a unique user ID, strong
         password, OTP, and/or certificate.
      ●​ Password Management: Employees are required to change passwords regularly according to the Sendbird Password
         Policy. The policy defines and configures the corporate password requirements including complexity, length, history,
         and duration.
      ●​ Endpoint Management: The Trust and Safety team monitors, manages and restricts all workstations and mobile
         devices that are used to access the company's system. All workers - regular employees and independent contractors -
         must install an endpoint protection agent that consists of anti-malware, intrusion prevention, and a firewall. Endpoint
         protection has an administrative console that allows the Trust and Safety team to monitor any employee's access and
         events within the Sendbird system environment.
      3.​ Change Management
      ●​ Development: In the event of software releases, the company uses a proprietary ticketing system to document
         procedures for tracking, testing, approving, and validating. A change management project is created when the
         ticketing system tracks activities from software development and customer requests. Any changed source code is
         reviewed and approved before it is released to the production environment by using proprietary tools such as GitHub
         and CircleCI.
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      ●​ Tracking: All audit logs are recorded for easy tracking of the changes in the ticketing system. The Trust and Safety
         team regularly checks these logs to make sure procedures comply with system change management. Sendbird also
         maintains updates to management policies regarding security code reviews and emergency fixes.
      ●​ Vulnerability Management: Sendbird operates its own vulnerability management program that actively investigates
         security vulnerabilities using a combination of automated scans and penetration tests. Automated scans identify all
         types of vulnerabilities in the software, system, and network components. Once vulnerabilities are identified, the
         vulnerability management program classifies and remediates vulnerabilities across all Sendbird services. Sendbird
         also takes corrective actions when necessary, based on the results of our annual penetration tests conducted by an
         external independent third party.
      4.​ Customer Data Security
      ●​ Encryption: Sendbird stores all types of data in the AWS relational database and the data are protected by strong
         encryption at rest and in transit. AWS provides data-at-rest options and key management to support the encryption
         process for stored data. Sendbird uses the latest recommended secure cipher suites to encrypt all traffic in transit,
         including the use of TLS 1.2 protocols, AES-256 encryption. Data at rest in AWS relational database are also
         encrypted by AES-256 encryption standards. And also, Sendbird uses the AWS Key Management Service (KMS) for
         handling the lifecycle of the data encryption key, which applies access controls for the key's generation, usage, and
         revocation.
      ●​ Incident Management: The Trust and Safety team has established protocols and guidelines for responding to
         emergency security incidents. All incidents are thoroughly investigated, documented, and reported to our Incident
         Response team for timely mitigation, including suspected or known violations of privacy and security.
      ●​ Security Awareness Training. Sendbird shall ensure that its personnel receive appropriate training on data protection
         and information security upon hire or onboarding, and on annual basis thereafter. Sendbird shall provide timely
         notices to its personnel of updates to its data protection and security policies.
      ●​ Retention: Sendbird's Data Classification and Protection Matrix classifies Customer Data into seven categories and
         defines security controls, handling methods, and retention period for each data category. We provide this paper to
         customers under a mutual NDA agreement. The contract and service licensing agreement signed between Sendbird
         and a client sets out the duration of how long Sendbird retains Customer Data after the termination of the contract.
         Customer Data will be removed from the Sendbird server accordingly.
      5.​ Business Continuity
      ●​ Business Continuity Plan: Business Continuity Planning (BCP) has been established for Sendbird services, which
         provides detailed procedures for recovery and reconstitution of systems known as Recovery Time Objectives (RTOs)
         and Recovery Point Objectives (RPOs). The BCP focuses on monitoring its sub-service organization (AWS),
         protecting Sendbird employees, and reallocating resources. Our BCP is reviewed on an annual basis.
      ●​ Disaster Recovery Drills: The engineering department conducts annual business continuity and disaster recovery
         drills to test communication plans, fail-over scenarios, operational transition, and other emergency responses. All
         teams that participate in the business continuity and disaster recovery exercise develop drill plans and post-mortems.
      ●​ Data Backup Management: All Customer Data is replicated to protect the availability of Sendbird’s services. Data
         replication occurs within the same region of AWS in which the client’s service is hosted. Sendbird typically
         configures the replication between one primary server and one secondary server within the same region. This
         replication provides multiple zones of availability. Sendbird uses AWS RDS Multi-AZ deployments to provide
         availability and durability for database (DB) instances. Upon provisioning a Multi-AZ DB instance, a primary DB
         instance is automatically created and synchronously replicates the data to a standby instance in a different
         availability zone (AZ). With reference to data replication, Sendbird services can resume database operations right
         after failover is completed. Furthermore, Sendbird services operate globally on multiple AWS regions and
         availability zones within each of those regions. Resources, such as database instances and Customer Data, are
         backed up and managed by AWS RDS on a region basis.

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 Schedule 3 – Additional Jurisdiction-Specific Terms
 A.​ South Korea. The following Section shall apply only to the extent the processing of Customer Data is subject to the Korean
     Personal Information Protection Act, as supplemented by the Enforcement Decree (“PIPA”). Customer is the “personal
     information controller” and Sendbird is the “person entrusting”, as those terms are defined under PIPA.

    1.​ Section 7 of the DPA is replaced with the following:
                7. Subprocessors. Sendbird will not engage any sub-processors without notifying Customer and obtaining
                Customer’s prior written authorization. Customer may object to the use of such Subprocessor in its absolute
                discretion. Notwithstanding the foregoing, Customer hereby authorizes those sub-processors listed at
                https://sendbird.com/sub-processors on the date that Sendbird and Customer enter into the Contract, provided
                that any subsequent changes to this list of pre-approved sub-processors must be authorized by Customer. Sendbird
                will ensure that all sub-processors have entered into a written agreement that is no less protective than this DPA.
                Sendbird will be fully liable for the acts and omissions of any sub-processors to the same extent as if the acts were
                performed, or omissions were made, by Sendbird.

 B.​ United States. Children's Online Privacy Protection Act (COPPA). The following Section shall apply only to the extent that
     Customer Data includes personal information from children under the age of 13, as defined under the U.S. Children's Online
     Privacy Protection Act and its implementing regulations ("COPPA").
     Customer represents and warrants that it has provided all notices, obtained and maintains all verifiable parental consents and
     other consents, and otherwise complied with all obligations required under COPPA and other applicable laws relating to
     children’s privacy in connection with Customer’s use of the Services and Sendbird’s processing of personal information from
     children under 13.
     The parties understand that, to the extent Sendbird processes personal information from children under 13 under this Section,
     Sendbird does so to provide support for the internal operations of Customer’s website or online service, as that term is
     defined under COPPA, including as applicable to maintain or analyze the functioning of the website or online service,
     perform network communications, authenticate users or personalize content, protect the security or integrity of users, the
     website, online service, or Services, ensure legal or regulatory compliance, or otherwise provide the Services as documented
     in the Contract.
     Sendbird will not use or disclose personal information from children under 13 to contact a specific individual, engage in
     behavioral advertising, amass a profile on a specific individual, or for any purpose other than providing support for the
     internal operations of Customer’s website or online service, providing the Services in accordance with Customer’s
     documented instructions, or as otherwise permitted by COPPA.
     Before allowing any sub-processor, service provider, operator, or other third party to collect or maintain personal information
     from children under 13 on Sendbird’s behalf, or before releasing such personal information to such entity, Sendbird will take
     reasonable steps to determine that the entity is capable of maintaining the confidentiality, security, and integrity of such
     information and will obtain written assurances that the entity will employ reasonable measures to maintain the
     confidentiality, security, and integrity of such information.

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