Third Party Index

Snapshot 44509

Document
Subprocessor list
URL
https://vartion.com/wp-content/uploads/2026/09/DPA_Updated.pdf#subprocessors
Fetched
HTTP status
200
Content type
application/pdf
Fetch mode
pdf
Size
346437 bytes
SHA-256 (raw)
6bb1c5b3664f58e53111568e98078ae253c4f3d6f834a69b41bad831ba17a821
SHA-256 (normalized text)
0f3bdfe86eaf11a40a09a4f3a2a2b4a4583a952433d262a725cf4174c7397472

Normalized text

Scripts and page chrome removed; this is what change detection compares.

                          DATA PROCESSING ADDENDUM

Addendum A: DATA PROCESSING TERMS FOR WITHIN THE EEA AND UK

GENERAL

1      Applicability and capacity

1.1.      These Data Processing Terms are applicable if the Client is a sole proprietorship,
          partnership or entity organized under its applicable law but located and having its
          principle office in any country within the EEA or UK.

1.2.      Vartion can be both a Data Controller and Data Processor with providing the
          Software and/or Services. Depending on the different aspects of the Service
          and/or Software Vartion shall either be Data Controller or Data Processor. For
          instance:
          (a) In case of Software being modified due to the generating and analysing of
              Personal Data entered into the system by the Client, Vartion considers itself
              a Data Controller. The Client is a Data Controller with regard to the Software
              or the Service.
          (b) With regard to Pascal onboarding, Pascal screening and Pascal transaction
              monitoring Vartion shall be considered a Data Processor and the Client a Data
              Controller.
          (c) With regard to the provision of Services, either related to the Software or
              otherwise, Vartion shall be a Data Processor, except when agreed otherwise.
              The Client shall be a Data Controller and instruct Vartion as to how to use the
              Personal Data.
          (d) In the instances that Vartion can instruct or use the Personal Data for its own
              means, Vartion shall be considered a Data Controller. The Client shall also be
              considered a Data Controller in these instances.

1.3.      In the case that Vartion exports Personal Data it is considered a Data Exporter and
          the Client the Data Importer. In case Vartion imports Personal Data it is
          considered a Data Importer and the Client is considered a Data Exporter. Parties
          can be regarded both Data Exporter and Data Importer within the same
          Agreement. For instance:

     1/
Page 38
            (a) With regard to the Software and SaaS-Service Vartion is the Data Importer
                when the Personal Data is entered into the system of the Software. Vartion is
                regarded a Data Exporter when Vartion generates and displays results to the
                Client in which case the Client is the Data Importer; and
            (b) With regard to the Services the Personal Data that is provided by the Client to
                Vartion the Client is Data Exporter and Vartion Data Importer. If Vartion
                processes the provided Personal Data and the Client gets access to the
                processed Personal Data, Vartion is considered a Data Exporter and the Client
                a Data Importer.

1.4.        In any case Annex I up and until Annex III shall be applicable. For each specific
            processing of Personal Data the applicable module shall apply.

1.5.        If there is any contradiction between the Agreement, General Terms and
            Conditions, the Data Processing Terms or the Annexes, the following order shall
            apply:

            1.   the Annexes;
            2.   these Data Processing Terms;
            3.   the Agreement; and lastly
            4.   the General Terms and Conditions.

1.6.        if the selection that the Parties are Controllers, Processors or Sub-Processors is
            wrong (either as a matter of fact or as a result of applying the EU Data Protection
            Laws) then:
             (a) the terms and conditions of the Data Processing Terms which apply to the
                 correct option which was not selected will apply; and
             (b) the Parties and any relevant Data Subjects are entitled to enforce the terms
                 and conditions of Data Processing Terms which apply to that correct option.

2      Term of Processing

2.1         The term for processing is as long as the Agreement is into place and it is necessary
            to process the Personal Data to execute the Agreement, hereinafter the Term of
            Processing.

Page 2/38
OPTION 1: VARTION IS DATA PROCESSOR AND CLIENT IS DATA CONTROLLER

1      Data deletion

1.1.        If the Client does not have the option to delete Personal Data during the provision
            of Software and related technical support and/or Services, Vartion will comply
            with any reasonable request from the Client to enable the deletion of such data,
            to the extent possible considering the nature and functionality of the Processing
            Services. This shall not apply when storage is required by Applicable Law.

1.2.        Upon expiration of the term of the Agreement, the Client hereby instructs Vartion
            to delete or return all Personal Data provided by the Client, in accordance with
            Applicable Law. Vartion shall delete all copies of the Personal Data from Vartion's
            systems. Vartion will comply with this instruction as soon as reasonably
            practicable unless: (i) storage is required by the Applicable Law, or (ii) the
            Agreement has been continued in or replaced by a new agreement or terms
            between Client and Vartion relating to Client's use of the Services and Client
            confirms that the processing of Client's Personal Data should continue in
            accordance with these Data Processing Terms.

2      Security measures

2.1.        Vartion does not guarantee that its security measures shall be effective under all
            possible circumstances.

2.2.        Vartion will implement such measures to ensure a level of security appropriate to
            the risk involved, such as:
             (a) the pseudonymisation and encryption of Personal Data;
             (b) the ability to ensure the ongoing confidentiality, integrity, availability and
                  resilience of processing systems and services;
             (c) the ability to restore the availability and access to Personal Data in a timely
                  manner in the event of a physical or technical incident; and
             (d) a process for regularly testing, assessing and evaluating the effectiveness of
                  the security measures.
    2.3.      Vartion takes reasonable measures to isolate and protect the Personal Data. A
              list of security measures is added in Annex II.

Page 3/38
3      Data incidents

3.1.        In the case that Vartion has become aware of a Data Incident, Vartion will: (i)
            promptly and without delay notify the Client of the Data Incident; and (ii)
            promptly take reasonable steps to minimize the damage and secure the Personal
            Data.

3.2.        The notification as mentioned in Clause 3.1. sub (i) will include a description of
            the Data Incident, the involved Data Subject and the Personal Data to the extent
            that a description is possible. This shall include the measures that have been taken
            by Vartion, the potential risks and a suggestion of the measures the Client can
            undertake to address the Data Incident, including, where appropriate, measures
            to mitigate any adverse consequences thereof.

3.3.        The notification and information will be disclosed to the contact information as
            has been disclosed to Vartion.

3.4.        Immediately following any accidental, unauthorised or unlawful Personal Data
            processing or Data Incident, the Parties will co-ordinate with each other in order
            to investigate the matter. Vartion and the Client can enter into negotiation on the
            possible assistance of the Client's handling of the matter.

3.5.        The Client is solely responsible for complying with Data Incident reporting
            legislations applicable to Client and complying with any reporting obligations to
            third parties in connection with Applicable Law.

3.6.        If Vartion incurs any additional costs for complying with this Clause 3 it is entitled
            to invoice the Client, at rates applicable at the time.

3.7.        Notice of or response to a Data Incident by Vartion under this Clause 3 shall not
            be construed as an admission by Vartion of fault and/or liability with respect to
            the Data Incident.

4      Responsibilities of the Client

4.1.        The Client acknowledges its own responsibilities with regard to EU Data
            Protection Laws and other Applicable Law.

Page 4/38
4.2.        Vartion has no obligation to protect the Personal Data that Client elects to store
            or transfer outside the systems of Vartion and that of Vartion’s sub-processors.

4.3.        The Client shall use the Services and ensure a level of security appropriate to the
            risk associated with the Personal Data.

4.4.        The Client shall secure authentication credentials of accounts, systems and
            devices used by Client to access and use the Services.

4.5.        The Client confirms that the security measures taken and maintained by Vartion,
            as described in the Data Processing Terms, provide a level of security appropriate
            to the risk regarding the Personal Data.

5      Audit rights and assessment

5.1.        If the Client has grounds to believe that the Personal Data is not being processed
            in accordance with the Processing Terms, then Vartion will give all necessary and
            reasonable assistance to an independent expert in case of an audit which audit’s
            scope is limited to verifying the Vartion’s compliance with its obligations under
            the Data Processing Terms and the Client has notified Vartion of the reasons for
            conducting such an audit.

5.2.        Vartion has the right to object against a third-party auditor when Vartion’s
            reasonable opinion, is not properly qualified or independent, is a competitor of
            Vartion or is otherwise manifestly unsuitable.

5.3.        In the event of such an objection by Vartion, Vartion shall appoint another auditor
            or conduct the audit itself. The Client shall contact Vartion for an audit. The start
            date and end date and further specifications of such audit shall be discussed and
            agreed upon by the Parties.

5.4.        Vartion shall not comply with instructions from the auditor if Vartion deems such
            instructions to be inconsistent with EU Data Protection Laws or Applicable Law.

5.5.        Vartion is not obliged to disclose any information which regards the data of other
             Clients, accounting and financial statement of Vartion, Vartion’s company

Page 5/38
             secrets, trade secrets, any information which could endanger the security of
             Vartion’s systems, any information which could result in Vartion breaching her
             legal obligations, or any information to which the Client or its third-party auditor
             wishes to obtain access for any reason other than good faith compliance with
             the Client's obligations under the EU Data Protection Laws.

5.6.        The expert shall be bound by a duty of confidentiality with regard to the findings
            in relation to such audit and shall only notify the Client of matters which cause
            Vartion to fail to comply with its obligations under the Processing Terms. The
            expert shall provide Vartion with a copy of the rapport relating to such audit.

6      Rights of the Data Subjects

6.1.        When Vartion receives a request from a Data Subject in connection with the
            Personal Data, Vartion will refer the Data Subject to submit his/her/its request to
            the Client. Client shall be responsible for responding to such request.

6.2.        Vartion will notify the Client of requests or complaints related to the Processing
            and will assist the Client in responding to any complaint, notice, communication
            or Data Subject request, in accordance with article 28(3)(e) of the EU Data
            Protection Laws.

6.3.        Vartion will take such technical and organisational measures as may be
            reasonable and appropriate, and may provide such necessary information to the
            Client to enable the Client to comply with its legal obligations concerning:

            a) the rights of data subjects under the EU Data Protection Laws and other data
               protection legislation, including, but not limited to, subject access rights, the
               rights to rectify, the right to data portability and erasure of Personal Data,
               object to the processing and automated processing of Personal Data, and
               restrict the processing of Personal Data; and
            b) information or assessment notices served by the Commissioner or other
               relevant Supervisory Authority on the Client related to its Personal Data
               obligations under the Applicable Law.

6.4.        If the Client is required to carry out a Data Protection Impact assessment or a
            subsequent consultation within the meaning of articles 35 and 36 of the EU Data
            Protection Laws, then Vartion shall endeavour to cooperate therewith.

Page 6/38
7      Data transfers

7.1.        Vartion will not transfer or otherwise process the Personal Data outside the UK or
            the EEA, without obtaining the Client’s prior written consent. This consent shall
            not unreasonably be withheld.

8      Data Liability

8.1         Notwithstanding any provision in the Agreement to the contrary, the aggregate
            liability of each party to the other party under or in connection with these Data
            Processing Agreement shall be limited to the maximum amount to which the
            Party's liability under the Agreement is limited.

8.1.1       Administrative fines imposed on the Client by a Supervisory Authority cannot be
            recovered from Vartion.

9      Sub-processors

The Client provides Vartion hereby with a general authorisation to engage sub-processors.
Vartion will ensure that its sub-processors will adhere to the same standard as this
Agreement holds.

Page 7/38
OPTION 2: BOTH PARTIES ARE CONTROLLER

1     Applicability

1.1         Due to the fact that both Parties are a controller in this instance, but depending
            on the specific Personal Data related activity is either an exporter or importer of
            Personal Data, the terms Data Exporter and Data Importer shall be used, either
            meaning Vartion or the Client depending on the circumstances.

1.2         The Data Importer shall process the Personal Data only for the specific
            purpose(s) of the transfer, as set out in Annex I.

1.3         Personal Data can be processed by modifying, retrieving, using, disclosing,
            merging, erasing and destroying Personal Data for the purpose of providing
            the Software and in some instances Services in accordance with these Data
            Processing Terms.

1.4         Vartion can also process the Personal Data that has been generated by use of
            the Service or Software by the Client or User. Vartion will only process the
            Personal Data to the extent, and in such a manner, as is necessary for the
            Agreement and aligns with the purpose of processing as set out in Annex I.

1.5         The Client retains control of the Personal Data and remains responsible for
            its compliance obligations under EU Data Protection Laws and other data
            protection laws, and the Client will ensure that the Client has any required
            notices and consents in place to enable lawful processing of the Personal
            Data by the Client.

1.6         References to certain Articles are references to the relevant articles in the EU
            Data Protection Laws.

2 Transparency

2.1         In order to enable data subjects to effectively exercise their rights pursuant to
            Clause 7, the Data Importer shall inform them, either directly or through the Data
            Exporter:

            (a) the identity and the contact details of the controller and, where applicable,
                of the controller's representative;

Page 8/38
            (b) the contact details of the data protection officer, where applicable;

            (c) the purposes of the processing for which the personal data are intended as
                well as the legal basis for the processing;

            (d) the categories of personal data concerned;

            (e) the recipients or categories of recipients of the personal data, if any;

            (f) where applicable, that the controller intends to transfer personal data to a
                recipient in a third country or international organisation and the existence
                or absence of an adequacy decision by the Commission, or in the case of
                transfers referred to in Article 46 or 47, or the second subparagraph of
                Article 49(1), reference to the appropriate or suitable safeguards and the
                means to obtain a copy of them or where they have been made available.

2.2         In addition to the information referred to in Clause 2.1, the Data Importer shall
            provide the data subject with the following information necessary to ensure fair
            and transparent processing in respect of the data subject:

            (a) the period for which the personal data will be stored, or if that is not
                possible, the criteria used to determine that period;

            (b) where the processing is based on point (f) of Article 6(1), the legitimate
                interests pursued by the controller or by a third party;

            (c) the existence of the right to request from the controller access to and
                rectification or erasure of personal data or restriction of processing
                concerning the data subject and to object to processing as well as the right
                to data portability;

            (d) where processing is based on point (a) of Article 6(1) or point (a) of Article
                9(2), the existence of the right to withdraw consent at any time, without
                affecting the lawfulness of processing based on consent before its
                withdrawal;

            (e) the right to lodge a complaint with a supervisory authority;

            (f) from which source the personal data originate, and if applicable, whether it
                came from publicly accessible sources;

            (g) the existence of automated decision-making, including profiling, referred to
                in Article 22(1) and (4) and, at least in those cases, meaningful information

Page 9/38
                 about the logic involved, as well as the significance and the envisaged
                 consequences of such processing for the data subject.

2.3      The Data Importer shall provide the information referred to in Clauses 2.1 and
         2.2:

             (a) within a reasonable period after obtaining the personal data, but at the
                 latest within one month, having regard to the specific circumstances in
                 which the personal data are processed;

             (b) if the personal data are to be used for communication with the data subject,
                 at the latest at the time of the first communication to that data subject; or

             (c) if a disclosure to another recipient is envisaged, at the latest when the
                 personal data are first disclosed.

2.4      Where the Data Importer intends to further process the personal data for a
         purpose other than that for which the personal data were obtained, the
         controller shall provide the data subject prior to that further processing with
         information on that other purpose and with any relevant further information as
         referred to in Clause 2.

2.5      Clause 2.1 up and until 2.4 shall not apply where and insofar as:

             (a) the data subject already has the information;

             (b) the provision of such information proves impossible or would involve a
                 disproportionate effort, in particular for processing for archiving purposes
                 in the public interest, scientific or historical research purposes or statistical
                 purposes, subject to the conditions and safeguards referred to in Article
                 89(1) or in so far as the obligation referred to in paragraph 1 of this Article
                 is likely to render impossible or seriously impair the achievement of the
                 objectives of that processing. In such cases the controller shall take
                 appropriate measures to protect the data subject's rights and freedoms and
                 legitimate interests, including making the information publicly available;

             (c) obtaining or disclosure is expressly laid down by Union or Member State
                 law to which the controller is subject and which provides appropriate
                 measures to protect the data subject's legitimate interests; or

             (d) where the personal data must remain confidential subject to an obligation
                 of professional secrecy regulated by Union or Member State law, including

Page 10/38
             a statutory obligation of secrecy.

3 Accuracy and data minimisation

3.1      Each Party shall ensure that the personal data is accurate and, where necessary,
         kept up to date. The Data Importer shall take every reasonable step to ensure that
         personal data that is inaccurate, having regard to the purpose(s) of processing, is
         erased or rectified without delay.

3.2      If one of the Parties becomes aware that the personal data it has transferred or
         received is inaccurate, or has become outdated, it shall inform the other Party
         without undue delay.

3.3      The Data Importer shall ensure that the personal data is adequate, relevant and
         limited to what is necessary in relation to the purpose(s) of processing.

4 Storage limitation

4.1      The Data Importer shall retain the personal data for no longer than necessary
         for the purpose(s) for which it is processed, in this case the provision of Service
         and/or Software on the Agreement. It shall put in place appropriate technical or
         organisational measures to ensure compliance with this obligation, including
         erasure or anonymisation of the data and all back-ups at the end of the retention
         period.

5 Security of processing

5.1      The Parties have agreed on the technical and organizational measures set out in
         Annex II. The Data Importer shall carry out regular checks to ensure that these
         measures continue to provide an appropriate level of security.

5.2      The Data Importer shall ensure that persons authorized to process the personal
         data have committed themselves to confidentiality or are under an appropriate
         statutory obligation of confidentiality.

5.3      In the event of a personal Data Breach concerning personal data processed by
         the Data Importer under these Clauses, the Data Importer shall take appropriate

Page 11/38
         measures to address the personal data breach, including measures to mitigate
         its possible adverse effects.

5.4      In case of a personal data breach that is likely to result in a risk to the rights and
         freedoms of natural persons, the Data Importer shall without undue delay notify
         both the Data Exporter and the competent supervisory authority pursuant to
         Clause10.1. Such notification shall contain i) a description of the nature of the
         breach (including, where possible, categories and approximate number of data
         subjects and personal data records concerned), ii) its likely consequences, iii) the
         measures taken or proposed to address the breach, and iv) the details of a
         contact point from whom more information can be obtained. To the extent it is
         not possible for the Data Importer to provide all the information at the same
         time, it may do so in phases without undue further delay.

5.5      In case of a personal data breach that is likely to result in a high risk to the rights
         and freedoms of natural persons, the Data Importer shall also notify without
         undue delay the data subjects concerned of the personal data breach and its
         nature, if necessary in cooperation with the Data Exporter, together with the
         information referred to in Clause 5.4., points ii) to iv), unless the Data Importer
         has implemented measures to significantly reduce the risk to the rights or
         freedoms of natural persons, or notification would involve disproportionate
         efforts. In the latter case, the Data Importer shall instead issue a public
         communication or take a similar measure to inform the public of the personal
         data breach.

5.6      The Data Importer shall document all relevant facts relating to the personal data
         breach, including its effects and any remedial action taken, and keep a record
         thereof.

6 Sensitive data

6.1      Where the transfer 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 or offences (hereinafter ‘sensitive data’),
         the Data Importer shall apply specific restrictions and/or additional safeguards

Page 12/38
         adapted to the specific nature of the data and the risks involved. This may
         include restricting the personnel permitted to access the personal data,
         additional security measures (such as pseudonymisation) and/or additional
         restrictions with respect to further disclosure.

7 Data Subject Rights

7.1      The Data Importer, where relevant with the assistance of the Data Exporter, shall
         deal with any enquiries and requests it receives from a data subject relating to
         the processing of his/her personal data and the exercise of his/her rights under
         these Clauses without undue delay and at the latest within one month of the
         receipt of the enquiry or request. The Data Importer shall take appropriate
         measures to facilitate such enquiries, requests and the exercise of data subject
         rights. Any information provided to the data subject shall be in an intelligible and
         easily accessible form, using clear and plain language.

7.2      In particular, upon request by the data subject the Data Importer shall, free of
         charge:
          (a) provide confirmation to the data subject as to whether personal data
              concerning him/her is being processed and, where this is the case, a copy
              of the data relating to him/her and the information in Annex I; if personal
              data has been or will be onward transferred, provide information on
              recipients or categories of recipients (as appropriate with a view to
              providing meaningful information) to which the personal data has been or
              will be onward transferred, the purpose of such onward transfers and their
              ground; and provide information on the right to lodge a complaint with a
              supervisory authority in accordance with Clause 10.1;
          (b) rectify inaccurate or incomplete data concerning the data subject;
          (c) erase personal data concerning the data subject if such data is being or has
              been processed in violation of any of these Clauses ensuring third-party
              beneficiary rights, or if the data subject withdraws the consent on which
              the processing is based.

7.3      Where the Data Importer processes the personal data for direct marketing
         purposes, it shall cease processing for such purposes if the data subject objects
         to it.

Page 13/38
7.4      The Data Importer shall not make a decision based solely on the automated
         processing of the personal data transferred (hereinafter ‘automated decision’),
         which would produce legal effects concerning the data subject or similarly
         significantly affect him/her, unless with the explicit consent of the data subject
         or if authorised to do so under the laws of the country of destination, provided
         that such laws lays down suitable measures to safeguard the data subject’s rights
         and legitimate interests. In this case, the Data Importer shall, where necessary
         in cooperation with the Data Exporter:
          (a) inform the data subject about the envisaged automated decision, the
               envisaged consequences and the logic involved; and
          (b) implement suitable safeguards, at least by enabling the data subject to
               contest the decision, express his/her point of view and obtain review by a
               human being.

7.5      Where requests from a data subject are excessive, in particular because of their
         repetitive character, the Data Importer may either charge a reasonable fee
         considering the administrative costs of granting the request or refuse to act on
         the request.

7.6      The Data Importer may refuse a data subject’s request if such refusal is allowed
         under the laws of the country of destination and is necessary and proportionate
         in a democratic society to protect one of the objectives listed in Article 23(1) of
         Regulation (EU) 2016/679.

7.7      If the Data Importer intends to refuse a data subject’s request, it shall inform the
         data subject of the reasons for the refusal and the possibility of lodging a
         complaint with the competent supervisory authority and/or seeking judicial
         redress.

7.8      The Data Importer shall inform data subjects in a transparent and easily
         accessible format, through individual notice or on its website, of a contact point
         authorised to handle complaints. It shall deal promptly with any complaints it
         receives from a data subject.

Page 14/38
8 Liability

8.1      Each Party shall be liable to the other Party/ies for any damages it causes the
         other Party/ies by any breach of these Clauses.

8.2      Each Party shall be liable to the data subject, and the data subject shall be
         entitled to receive compensation, for any material or non-material damages that
         the Party causes the data subject by breaching the third-party beneficiary rights
         under these Clauses. This is without prejudice to the liability of the Data Exporter
         under Regulation (EU) 2016/679.

8.3      Where more than one Party is responsible for any damage caused to the data
         subject as a result of a breach of these Clauses, all responsible Parties shall be
         jointly and severally liable and the data subject is entitled to bring an action in
         court against any of these Parties.

8.4      The Parties agree that if one Party is held liable under Clause 8.3 it shall be
         entitled to claim back from the other Party/ies that part of the compensation
         corresponding to its/their responsibility for the damage.

8.5      The Data Importer may not invoke the conduct of a processor or sub-processor
         to avoid its own liability.

9 Dispute resolution

9.1      In case of a dispute between a data subject and one of the Parties as regards
         compliance with these Clauses, that Party shall use its best efforts to resolve the
         issue amicably in a timely fashion. The Parties shall keep each other informed
         about such disputes and, where appropriate, cooperate in resolving them.

9.2      Where the data subject invokes a third-party beneficiary right pursuant to Clause
         3, the Data Importer shall accept the decision of the data subject to:

             (a) lodge a complaint with the supervisory authority in the Member State of
                 his/her habitual residence or place of work, or the competent supervisory
                 authority pursuant to Clause 1§0.1l;

Page 15/38
             (b) refer the dispute to the competent courts within the meaning of Clause 19.2
                 of the General Terms and Conditions.
9.3      The Parties accept that the data subject may be represented by a not-for-profit
         body, organisation or association under the conditions set out in Article 80(1) of
         the EU Data Protections Laws.
9.4      The Data Importer shall abide by a decision that is binding under the applicable EU
         or Applicable Law.
9.5      The Data Importer agrees that the choice made by the data subject will not
         prejudice his/her substantive and procedural rights to seek remedies in
         accordance with applicable laws.

10 Supervisory authority

10.1         The supervisory authority with responsibility for ensuring compliance by the
             Data Exporter with the EU Data Protections Laws as regards the data transfer,
             as indicated in Annex I shall act as competent supervisory authority.

10.2         The Data Importer agrees to submit itself to the jurisdiction of and cooperate
             with the competent supervisory authority in any procedures aimed at ensuring
             compliance with these Clauses. In particular, the Data Importer agrees to
             respond to enquiries, submit to audits and comply with the measures adopted
             by the supervisory authority, including remedial and compensatory measures.
             It shall provide the supervisory authority with written confirmation that the
             necessary actions have been taken.

11 Warranties

11.1     The Parties warrant that they have no reason to believe that the laws and
         practices in the third country of destination applicable to the processing of the
         personal data by the Data Importer, including any requirements to disclose
         personal data or measures authorising access by public authorities, prevent the
         Data Importer from fulfilling its obligations under these Clauses. This is based on
         the understanding that laws and practices that respect the essence of the
         fundamental rights and freedoms and do not exceed what is necessary and

Page 16/38
         proportionate in a democratic society to safeguard one of the objectives listed
         in Article 23(1) of the EU Data Protections Laws, are not in contradiction with
         these Clauses.
11.2     The Parties declare that in providing the warranty in Clause 11.1 they have taken
         due account in particular of the following elements:
             (a) the specific circumstances of the transfer, including the length of the
                 processing chain, the number of actors involved and the transmission
                 channels used; intended onward transfers; the type of recipient; the
                 purpose of processing; the categories and format of the transferred
                 personal data; the economic sector in which the transfer occurs; the storage
                 location of the data transferred;
             (b) the laws and practices of the third country of destination– including those
                 requiring the disclosure of data to public authorities or authorising access
                 by such authorities – relevant in light of the specific circumstances of the
                 transfer, and the applicable limitations and safeguard;
             (c) any relevant contractual, technical or organisational safeguards put in place
                 to supplement the safeguards under these Clauses, including measures
                 applied during transmission and to the processing of the personal data in
                 the country of destination.

11.3     The Data Importer warrants that, in carrying out the assessment under Clause
         11.2 (b), it has made its best efforts to provide the Data Exporter with relevant
         information and agrees that it will continue to cooperate with the Data Exporter
         in ensuring compliance with these Clauses.

11.4     The Parties agree to document the assessment under Clause 11.2 and make it
         available to the competent supervisory authority on request.

11.5     The Data Importer agrees to notify the Data Exporter promptly if, after having
         agreed to these Clauses and for the duration of the contract, it has reason to
         believe that it is or has become subject to laws or practices not in line with the
         requirements under Clause 11.2, including following a change in the laws of the
         third country or a measure (such as a disclosure request) indicating an
         application of such laws in practice that is not in line with the requirements in
         Clause 11.2.

Page 17/38
11.6     Following a notification pursuant to Clause 11.5, or if the Data Exporter
         otherwise has reason to believe that the Data Importer can no longer fulfil its
         obligations under these Clauses, the Data Exporter shall promptly identify
         appropriate measures (e.g. technical or organisational measures to ensure
         security and confidentiality) to be adopted by the Data Exporter and/or Data
         Importer to address the situation. The Data Exporter shall suspend the data
         transfer if it considers that no appropriate safeguards for such transfer can be
         ensured, or if instructed by [for Module Three: the controller or] the competent
         supervisory authority to do so. In this case, the Data Exporter shall be entitled to
         terminate the contract, insofar as it concerns the processing of personal data
         under these Clauses. If the contract involves more than two Parties, the Data
         Exporter may exercise this right to termination only with respect to the relevant
         Party, unless the Parties have agreed otherwise. Where the contract is
         terminated pursuant to this Clause, Clause 13 shall apply.

12 Notification

12.1 The Data Importer agrees to notify the Data Exporter and, where possible, the
data subject promptly (if necessary with the help of the Data Exporter) if it:
             (a) receives a legally binding request from a public authority, including judicial
                 authorities, under the laws of the country of destination for the disclosure
                 of personal data transferred pursuant to these Clauses; such notification
                 shall include information about the personal data requested, the requesting
                 authority, the legal basis for the request and the response provided; or
             (b) becomes aware of any direct access by public authorities to personal data
                 transferred pursuant to these Clauses in accordance with the laws of the
                 country of destination; such notification shall include all information
                 available to the importer.

12.2     If the Data Importer is prohibited from notifying the Data Exporter and/or the
          data subject under the laws of the country of destination, the Data Importer
          agrees to use its best efforts to obtain a waiver of the prohibition, with a view
          to communicating as much information as possible, as soon as possible. The
          Data Importer agrees to document its best efforts in order to be able to
          demonstrate them on request of the Data Exporter.

Page 18/38
12.3     Where permissible under the laws of the country of destination, the Data
         Importer agrees to provide the Data Exporter, at regular intervals for the
         duration of the contract, with as much relevant information as possible on the
         requests received (in particular, number of requests, type of data requested,
         requesting authority/ies, whether requests have been challenged and the
         outcome of such challenges, etc.

12.4     The Data Importer agrees to preserve the information pursuant to this Clauses
          12 for the duration of the Agreement and make it available to the competent
          supervisory authority on request.

12.5         These Clauses are without prejudice to the obligation of the Data Importer to
             inform the Data Exporter promptly where it is unable to comply with these
             Clauses.

13 Review of legality and data minimization

13.1         The Data Importer agrees to review the legality of the request for disclosure, in
             particular whether it remains within the powers granted to the requesting
             public authority, and to challenge the request if, after careful assessment, it
             concludes that there are reasonable grounds to consider that the request is
             unlawful under the laws of the country of destination, applicable obligations
             under international law and principles of international comity. The Data
             Importer shall, under the same conditions, pursue possibilities of appeal. When
             challenging a request, the Data Importer shall seek interim measures with a
             view to suspending the effects of the request until the competent judicial
             authority has decided on its merits. It shall not disclose the personal data
             requested until required to do so under the applicable procedural rules. These
             requirements are without prejudice to the obligations of the Data Importer
             under Clause 12.

13.2          The Data Importer agrees to document its legal assessment and any challenge
             to the request for disclosure and, to the extent permissible under the laws of
             the country of destination, make the documentation available to the Data
             Exporter. It shall also make it available to the competent supervisory authority
             on request.

Page 19/38
13.3         The Data Importer agrees to provide the minimum amount of information
             permissible when responding to a request for disclosure, based on a reasonable
             interpretation of the request.

14 Non-compliance with the Clauses and termination

14.1     The Data Importer shall promptly inform the Data Exporter if it is unable to
          comply with these Clauses, for whatever reason.
14.2      In the event that the Data Importer is in breach of these Clauses or unable to
         comply with these Clauses, the Data Exporter shall suspend the transfer of
         personal data to the Data Importer until compliance is again ensured or the
         contract is terminated. This is without prejudice to Clause 12.
14.3    The Data Exporter shall be entitled to terminate the contract, insofar as it
        concerns the processing of personal data under these Clauses, where:
        (a) the Data Exporter has suspended the transfer of personal data to the Data
            Importer pursuant to Clause 14.2 and compliance with these Clauses is not
            restored within a reasonable time and in any event within one month of
            suspension;
        (b) the Data Importer is in substantial or persistent breach of these Clauses; or
        (c) the Data Importer fails to comply with a binding decision of a competent
            court or supervisory authority regarding its obligations under these Clauses.
14.4     In these cases, it shall inform the competent supervisory authority of such non-
         compliance. Where the contract involves more than two Parties, the Data
         Exporter may exercise this right to termination only with respect to the relevant
         Party, unless the Parties have agreed otherwise.
14.5     Personal data that has been transferred prior to the termination of the contract
         pursuant to Clause 14.3 shall at the choice of the Data Exporter immediately be
         returned to the Data Exporter or deleted in its entirety. The same shall apply to
         any copies of the data. The Data Importer shall certify the deletion of the data
         to the Data Exporter. Until the data is deleted or returned, the Data Importer
         shall continue to ensure compliance with these Clauses. In case of local laws
         applicable to the Data Importer that prohibit the return or deletion of the
         transferred personal data, the Data Importer warrants that it will continue to

Page 20/38
         ensure compliance with these Clauses and will only process the data to the
         extent and for as long as required under that local law.
14.6     Either Party may revoke its agreement to be bound by these Clauses where (i)
         the European Commission adopts a decision pursuant to Article 45(3) of the EU
         Data Protections Laws that covers the transfer of personal data to which these
         Clauses apply; or (ii) the EU Data Protections Laws become part of the legal
         framework of the country to which the personal data is transferred. This is
         without prejudice to other obligations applying to the processing in question
         under the EU Data Protections Laws.

Page 21/38
ADDENDUM B: DATA PROCESSING AGREEMENT FOR OUTSIDE THE EEA
AND UK
GENERAL

1      Applicability and capacity

1.1.      These Data Processing Terms are applicable if the Client is a sole proprietorship,
          partnership or entity organized under its applicable law but located and having its
          principle office in any country outside the EEA or UK.

1.2.      The Data Processing Agreement shall commence at the moment the Parties have
          signed the relevant Agreement.

1.3.      This Data Processing Terms are based on the European Standard Contractual
          Clauses and the UK Addendum published on 4 June 2021 and 21 March 2022
          (“SCC”) respectively, the relevant Clauses and modules apply as selected in Tabel
          1. The Data Processing Agreement consists out of these Clauses and Annex I. The
          UK Addendum can be accessed via our website Vartion

1.4.      If there is any contradiction between the Agreement, General Terms and
          Conditions, the Data Processing Agreement or the Annexes, the following order
          shall apply:

          1.   The SC and the Annexes;
          2.   these Data Processing Terms;
          3.   the Agreement; and lastly
          4.   the General Terms and Conditions.

1.5.      In the case that Vartion exports Personal Data it is considered a Data Exporter and
          the Client the Data Importer. In case Vartion imports Personal Data it is
          considered a Data Importer and the Client is considered a Data Exporter. Parties
          can be regarded both Data Exporter and Data Importer within the same
          Agreement. For instance:

          (a) With regard to the Software and Saas-Service Vartion is the Data Importer
              when the Personal Data is entered into the system of the Software. Vartion is

Page 22/38
             regarded a Data Exporter when Vartion generates and displays results to the
             Client in which case the Client is the Data Importer; and
         (b) With regard to the Services the Personal Data that is provided by the Client to
             Vartion the Client is Data Exporter and Vartion Data Importer. If Vartion
             processes the provided Personal Data and the Client gets access to the
             processed Personal Data, Vartion is considered a Data Exporter and the Client
             a Data Importer.

1.6.     Vartion can be both a Data Controller and Data Processor with providing the
         Software and/or Services. Depending on the different aspects of the Service
         and/or Software Vartion shall either be Data Controller or Data Processor. For
         instance:
         (a) In case of Software being modified due to the generating and analysing of
             Personal Data entered into the system by the Client, Vartion considers itself
             a Data Controller. The Client is a Data Controller with regard to the Software
             or the Service.
         (b) With regard to Pascal onboarding, Pascal screening and Pascal transaction
             monitoring, Vartion shall be considered a Data Processor and the Client a Data
             Controller.
         (c) With regard to the provision of Services, either related to the Software or
             otherwise, Vartion shall be a Data Processor, except when agreed otherwise.
             The Client shall be a Data Controller and instruct Vartion as to how to use the
             Personal Data.
         (d) In the instances that Vartion can instruct or use the Personal Data for its own
             means, Vartion shall be considered a Data Controller. The Client shall also be
             considered a Data Controller in these instances.

1.7.     In any case, regardless of each of the Parties capacity, Annex I shall be applicable.

1.8.     if the selection that the Parties are Controllers, Processors or Sub-Processors is
         wrong (either as a matter of fact or as a result of applying the EU Data Protection
         Laws) then:
         (a) the terms and conditions of the Data Processing Agreement which apply to
              the correct option which was not selected will apply; and
         (b) the Parties and any relevant Data Subjects are entitled to enforce the terms
              and conditions of Data Processing Agreement which apply to that correct
              option.

Page 23/38
2     Selected SCC
2.1         In table 1 the selected SCC are presented together with the additional
            information to complete the SCC.

Table 1: Selected SCCs, Modules and Selected Clauses

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

Module            Module in     Clause 7 Clause Clause 9a       Clause        Is personal
                  operation     (Docking 11      (Prior         9a            data received
                                Clause) (Option) Authorisation (Time          from the
                                                 or General     period)       Importer
                                                 Authorisation)               combined
                                                                              with
                                                                              personal
                                                                              data
                                                                              collected by
                                                                              the
                                                                              Exporter?

        1         Yes           No        No                                  Yes

        2         Yes           No        No        general          three  Yes
                                                    authorisation    months
                                                    (option 2)

        3

        4         Yes           No        No        not applicable            Yes

1.1.1

Page 24/38
Module       Module in   Clause 17         Clause 18
             operation

     1       Yes         the Netherlands the Netherlands

     2       Yes         the Netherlands the Netherlands

     3       Yes         the Netherlands

1.1.2

Page 25/38
ANNEX I

     DESCRIPTION OF TRANSFER

     MODULE ONE: Transfer controller to controller
     MODULE TWO: Transfer controller to processor
     MODULE THREE: Transfer processor to processor
     MODULE FOUR: Transfer processor to controller

     Categories of data subjects whose personal data is transferred

       Relevant Data             The categories of Data Subjects will update automatically if
       Subjects                  the information is updated in the Linked Agreement referred
                                 to.

                                 SECTION B: USE OF SERVICE
                                 The Data Subjects will be adults in accordance with the country
                                 or nationality.

                                 SECTION C: SAAS-SERVICE
                                 The Data Subjects will be adults in accordance with the country
                                 or nationality.

     Categories of personal data transferred

       Relevant Personal         The categories of Personal Data will update automatically if the
       Data                      information is updated in the Linked Agreement referred to.

                                 SECTION B: USE OF SERVICE
                                 Personal Data categories will be names, aka’s, address, date and
                                 place of birth, passport number(s), identity card number(s),

Page 26/38
                                  nationality(-ies), profession, or possibly any other background
                                  data generated by using the Software.

                                  SECTION C: SAAS-SERVICE
                                  Personal Data categories will be names, aka’s, address, date and
                                  place of birth, passport number(s), identity card number(s),
                                  nationality(-ies), profession, or any other background data
                                  generated by the Client using the Software.

     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.
                             Parties do not transfer Sensitive Data. If in any case the transfer
       Sensitive data
                             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 or offences, the Data Importer shall apply specific
                             restrictions and/or additional safeguards adapted to the specific
                             nature of the data and the risks involved. This may include restricting
                             the personnel permitted to access the personal data, additional
                             security measures (such as pseudonymisation) and/or additional
                             restrictions with respect to further disclosure. The measures
                             hereunder shall in any case be applied with data transferring.

       Security     of            -    Use of data segregation; and
       Transmission               -    Use of anonymization of data.

Page 27/38
       Security         of        -    the ability to restore the availability and access to Personal
       Storage                         Data in a timely manner in the event of a physical or technical
                                       incident; and
                                  -    Data backups (daily).

       Security         of        -    a process for regularly testing, assessing and evaluating the
       Processing                      effectiveness of the security measures;
                                  -    Physical access controls.
                                  -    System access controls.

       Organisational             -    Only the authorized employees of the Parties can access the
       security                        data. Parties only work with systems that: (i) only allow
       measures                        authorized individuals to access the Personal Data to which
                                       they have been granted access; and (ii) ensure that the
                                       Personal Data cannot be read, copied, modified or deleted
                                       without authorization during processing.
                                  -    All employees of the Parties are instructed to conduct
                                       themselves in a manner consistent with the Party’s guidelines
                                       regarding confidentiality, Personal Data protection, business
                                       ethics, appropriate use and professional standards; and
                                  -    Parties make use of password protection and use of
                                       passwords and two factor authentications.

       Technical                  -    Encryption of Personal Data;
       security                   -    Use of antivirus;
       minimum                    -    Use of Anti-Malware Software
       requirements

       Updates to the             -    The Security Requirements will update automatically if the
       Security                        information is updated in the Linked Agreement referred to.
       Requirements

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

Page 28/38
       Frequency of the         SECTION B: USE OF SERVICE
       transfer
                                During the Agreement, on various moments.

                                SECTION C: SAAS-SERVICE
                                The transfer shall happen when Personal Data is entered into the
                                system and in turn results are being generated with that Personal
                                Data, which is as frequent as the Client enters Personal Data into
                                the system.

                                Monitoring
                                In the case of Monitoring, the Client is able to choose the
                                frequency. With Monitoring the data transfer from new
                                generated results, with Vartion as Data Exporter, shall happen on
                                a more frequent basis which frequency is decided by the Client.

     Nature of the processing

       Nature of the            SECTION B: USE OF SERVICE
       processing
                                Vartion can process by collecting, capturing, organizing,
                                structuring, storing, modifying, retrieving, using, disclosing,
                                merging, erasing and destroying Personal Data for the purpose of
                                providing the Services and technical support to Client for
                                Software in accordance with these Data Processing Agreement.
                                Vartion will only process the Personal Data to the extent, and in
                                such a manner, as is necessary for the Agreement in accordance
                                with the instructions of the Client.

                                SECTION C: SAAS-SERVICE
                                Vartion processes Personal Data relating to individuals provided
                                to Vartion via the SaaS-Service, by (or at the direction of) the
                                Client or by its Users. Vartion can also process the Personal Data
                                that has been generated by use of the Service or Software by the
                                Client or User. Vartion will only process the Personal Data to the

Page 29/38
                                   extent, and in such a manner, as is necessary for the Agreement
                                   in accordance with the instructions of the Client.

     Purpose(s) of the data transfer and further processing

       Purpose                    SECTION B: SERVICE
                                  The purpose of processing Personal Data is to execute the
                                  relevant Agreement and the Services, which can also relate to
                                  assisting the Client with complying with its legal obligations with
                                  regard to Client Due Diligence.

                                  SECTION C: SAAS-SERVICE
                                  The purpose of processing Personal Data is to provide the Client
                                  certain service such as the filling in of the KYC-checklist with
                                  Pascal onboarding or give the Client the possibility to screen
                                  possible costumers itself for KYC purposes through and in
                                  connection with a tool designed and developed for the
                                  compliance with legal obligations such as to (1) support risk and
                                  compliance professionals during a Client due diligence (CDD), and
                                  if applicable (2) constantly monitor the Database – or any other
                                  database on which is de Software is applied by the Client – for
                                  Client related events (direct and indirect) and Client transactions,
                                  thereby boosting efficiency and providing insight into data, made
                                  available by Vartion to the Client via the internet or another
                                  network.

     The period for which the personal data will be retained, or, if that is not possible, the criteria used
     to determine that period

       Retention period           SECTION B: SERVICE
                                  Personal Data shall be detained as long as necessary for the
                                  execution of the Agreement. If the Agreement is terminated all

Page 30/38
                                  Personal Data shall be destroyed except for the Personal Data
                                  which has to be retained under Applicable Law.

                                  SECTION C: SAAS-SERVICE
                                  Personal Data shall be detained as long as necessary for the
                                  execution of the Agreement. If the Agreement is terminated all
                                  Personal Data shall be destroyed except for the Personal Data
                                  which has to be retained under Applicable Law or in case it has
                                  been reused to improve the Software.

      For transfers to (sub-) processors, also specify subject matter, nature and duration of the processing
                                 Asana, Inc. processes feedback provided by our users. By using
       List   of         sub-
                                 Pascal, you acknowledge and agree that your information is
       processors
                                 subject to Asana. Their privacy statement can be found at the
                                 following location: https://asana.com/terms/privacy-statement
                                 Processes user feedback, including user email addresses,
                                 usernames, organisation names, browser information, and written
                                 messages.

                                 Cloudflare, Inc. provides a proxy services for Pascal. By using
                                 Pascal, you acknowledge and agree that your information is
                                 subject to Cloudflare. Their privacy statement can be found at the
                                 following location: https://www.cloudflare.com/privacypolicy/
                                 Handles all encrypted internet traffic between clients and Pascal.

                                 DataChecker B.V. provides identity verification services in support
                                 of Pascal Onboarding and may process personal data in that
                                 capacity. Such processing is governed by DataChecker's applicable
                                 Privacy Statement and its General Terms and Conditions, available
                                 at: https://datachecker.nl/en/privacy-and-cookie-statement/ and
                                 https://datachecker.nl/en/general-terms-and-conditions/

Page 31/38
             DigitalOcean, LLC provides data storage of Pascal. By using Pascal,
             you acknowledge and agree that your information is subject to
             DigitalOcean. Their privacy statement can be found at the
             following location: https://www.digitalocean.com/legal/privacy-
             policy Stores all Pascal data, including PDF reports and backups of
             the application’s databases.

             Functional Software, Inc. (Sentry) provides application error
             monitoring and troubleshooting services in support of Pascal and
             may process limited personal data in that capacity. Such
             processing is governed by Sentry's applicable contractual data
             protection terms and Privacy Policy, available at:
             https://sentry.io/privacy/ and https://sentry.io/legal/dpa/

             HubSpot, Inc. provides customer services for Pascal. By using
             Pascal, you acknowledge and agree that your information is
             subject to HubSpot. Their privacy statement can be found at the
             following location: https://legal.hubspot.com/privacy-policy
             Supports customer service operations by processing user email
             addresses, usernames, organisation names, and account activity
             data.

             Microsoft B.V. provides hosting for our services and processes all
             our data. By using Pascal, you acknowledge and agree that your
             information is subject to Microsoft. Their privacy statement can be
             found at the following location: https://privacy.microsoft.com/en-
             gb/privacystatement Hosts and processes all Pascal data.

             Twilio Ireland Ltd. provides email services and processes emails
             send from Pascal. By using Pascal, you acknowledge and agree that
             your information is subject to Twilio. Their privacy statement can
             be found at the following location: https://www.twilio.com/en-
             us/legal/privacy Processes email services, including user email
             addresses and usernames.

Page 32/38
                          Userpilot, Inc. provides onboarding and adoption services for
                          Pascal. By using Pascal, you acknowledge and agree that your
                          information is subject to Userpilot. Their privacy statement can be
                          found at the following location: https://userpilot.com/privacy-
                          policy/ Manages onboarding and adoption services, processing
                          user email addresses, usernames, organisation names, browser
                          information, and account activity logs.

                          Veriff OÜ provides identity verification and fraud prevention
                          services in support of Pascal Onboarding and may process
                          personal data in that capacity. Such processing is governed by
                          Veriff's applicable contractual data protection terms and Privacy
                          Notice, available at: https://www.veriff.com/privacy-notice and
                          https://www.veriff.com/data-processing-addendum/ver-dpa-
                          2304

                       Processor shall notify Controller of any intended changes
       Changes of sub-
                       concerning the engagement or replacement of a sub-Processor.
       processors
                       The Controller shall be given thirty (30) days to object, duly
                       motivated and in writing. Consent shall not unreasonably be
                       withheld.

COMPETENT SUPERVISORY AUTHORITY

MODULE ONE: Transfer controller to controller
MODULE TWO: Transfer controller to processor
MODULE THREE: Transfer processor to processor

                                The competent supervisory Autority is the Autoriteit
       Competent
                                Persoonsgegevens (AP) located in the Netherlands.
       Supervisory
       Authority

Page 33/38
ANNEX II

TECHNICAL AND ORGANISATIONAL MEASURES INCLUDING TECHNICAL
AND ORGANISATIONAL MEASURES TO ENSURE THE SECURITY OF THE
DATA

MODULE ONE: Transfer controller to controller
MODULE TWO: Transfer controller to processor
MODULE THREE: Transfer processor to processor

 Security         of      -   Use of data segregation; and
 Transmission             -   Use of anonymization of data.

 Security of Storage      -   the ability to restore the availability and access to
                              Personal Data in a timely manner in the event of a physical
                              or technical incident; and
                          -   Data backups (daily).

 Security         of      -   a process for regularly testing, assessing and evaluating
 Processing                   the effectiveness of the security measures;
                          -   Physical access controls.
                          -   System access controls.

 Organisational           -   Only the authorized employees of the Parties can access
 security measures            the data. Parties only work with systems that: (i) only
                              allow authorized individuals to access the Personal Data
                              to which they have been granted access; and (ii) ensure
                              that the Personal Data cannot be read, copied, modified
                              or deleted without authorization during processing.
                          -   All employees of the Parties are instructed to conduct
                              themselves in a manner consistent with the Party’s
                              guidelines regarding confidentiality, Personal Data
                              protection, business ethics, appropriate use and
                              professional standards; and

Page 34/38
                      -   Parties make use of password protection and use of
                          passwords and two factor authentications.

 Technical security   -   Encryption of Personal Data;
 minimum              -   Use of antivirus;
 requirements         -   Use of Anti-Malware Software

 Updates to the       -   The Security Requirements will update automatically if
 Security                 the information is updated in the Linked Agreement
 Requirements             referred to.

Page 35/38
ANNEX III

LIST OF SUB-PROCESSORS
      MODULE TWO: Transfer controller to processor
      MODULE THREE: Transfer processor to processor

       List of sub- SECTION B: SERVICE
       processors

                          SECTION C: SAAS-SERVICE

                          Asana, Inc. processes feedback provided by our users. By using
                          Pascal, you acknowledge and agree that your information is
                          subject to Asana. Their privacy statement can be found at the
                          following location: https://asana.com/terms/privacy-statement
                          Processes user feedback, including user email addresses,
                          usernames, organisation names, browser information, and
                          written messages.

                          Cloudflare, Inc. provides a proxy services for Pascal. By using
                          Pascal, you acknowledge and agree that your information is
                          subject to Cloudflare. Their privacy statement can be found at the
                          following location: https://www.cloudflare.com/privacypolicy/
                          Handles all encrypted internet traffic between clients and Pascal.

                          DataChecker B.V. provides identity verification services in support
                          of Pascal Onboarding and may process personal data in that
                          capacity. Such processing is governed by DataChecker's applicable
                          Privacy Statement and its General Terms and Conditions, available
                          at: https://datachecker.nl/en/privacy-and-cookie-statement/ and
                          https://datachecker.nl/en/general-terms-and-conditions/

                          DigitalOcean, LLC provides data storage of Pascal. By using Pascal,
                          you acknowledge and agree that your information is subject to
                          DigitalOcean. Their privacy statement can be found at the
                          following location: https://www.digitalocean.com/legal/privacy-

Page 36/38
             policy Stores all Pascal data, including PDF reports and backups of
             the application’s databases.

             Functional Software, Inc. (Sentry) provides application error
             monitoring and troubleshooting services in support of Pascal and
             may process limited personal data in that capacity. Such
             processing is governed by Sentry's applicable contractual data
             protection terms and Privacy Policy, available at:
             https://sentry.io/privacy/ and https://sentry.io/legal/dpa/

             HubSpot, Inc. provides customer services for Pascal. By using
             Pascal, you acknowledge and agree that your information is
             subject to HubSpot. Their privacy statement can be found at the
             following location: https://legal.hubspot.com/privacy-policy
             Supports customer service operations by processing user email
             addresses, usernames, organisation names, and account activity
             data.

             Microsoft B.V. provides hosting for our services and processes all
             our data. By using Pascal, you acknowledge and agree that your
             information is subject to Microsoft. Their privacy statement can
             be       found         at     the        following       location:
             https://privacy.microsoft.com/en-gb/privacystatement Hosts and
             processes all Pascal data.

             Twilio Ireland Ltd. provides email services and processes emails
             send from Pascal. By using Pascal, you acknowledge and agree
             that your information is subject to Twilio. Their privacy statement
             can      be      found     at      the       following      location:
             https://www.twilio.com/en-us/legal/privacy Processes email
             services, including user email addresses and usernames.

             Userpilot, Inc. provides onboarding and adoption services for
             Pascal. By using Pascal, you acknowledge and agree that your
             information is subject to Userpilot. Their privacy statement can be
             found at the following location: https://userpilot.com/privacy-

Page 37/38
                         policy/ Manages onboarding and adoption services, processing
                         user email addresses, usernames, organisation names, browser
                         information, and account activity logs.

                         Veriff OÜ provides identity verification and fraud prevention
                         services in support of Pascal Onboarding and may process
                         personal data in that capacity. Such processing is governed by
                         Veriff's applicable contractual data protection terms and Privacy
                         Notice, available at: https://www.veriff.com/privacy-notice and
                         https://www.veriff.com/data-processing-addendum/ver-dpa-
                         2304

                       Processor shall notify Controller of any intended changes
       Changes of sub-
                       concerning the engagement or replacement of a sub-Processor.
       processors
                       The Controller shall be given thirty (30) days to object, duly
                       motivated and in writing. Consent shall not unreasonably be
                       withheld.

Page 38/38