Third Party Index

Snapshot 56004

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Subprocessor list
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1dd1f5939377df132603bf089b9d3f6a621967a76e51f673b4c6213a52412913

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

                                         LA GROWTH MACHINE
                                  DATA PROCESSING AGREEMENT

This Data Processing Agreement (hereinafter referred to as the “DPA”) is concluded between La Growth
Machine and the Client who has accepted the La Growth Machine General Terms and Conditions (hereinafter
referred to as the “Terms of Services”), by subscribing to the services available through La Growth Machine
(the “Services”).

The DPA will come into force on the same date as the Terms of Services, and for the duration of the Terms
of Services.

La Growth Machine and the Client are hereafter collectively referred to as the “Parties” and individually as a
“Party”.

In relation to the use of the Services, each of the Parties is required to process personal data in various ways.

By means of the DPA, the Parties wish to identify said processing, the rules applicable to the latter and their
respective roles with regard to the law applicable to the protection of personal data.

Article 1    DEFINITIONS

Unless otherwise expressly stated in the DPA, the terms “Personal Data”, “Data Subjects”, “Data
Controller”, “Data Processor”, and “Personal Data Breach” shall have the meaning provided for in the
Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection
of natural persons with regard to the processing of personal data and on the free movement of such data
(hereinafter referred to as the “GDPR”).

In addition, it is stated that terms used in the DPA with a capital letter shall have the same meaning as in the
Terms of Services.

In addition, the following terms will have the following definitions in the DPA:

1.1     “Data Protection Law” shall mean all national, European and international laws, regulations and
        other standards applicable to the Processing concerned, including in particular the GDPR and any
        national laws of the Member States of the European Union adopted in addition to or in application of
        the provisions of the GDPR, as well as, where applicable, the national, European and international
        laws, regulations and other standards applicable to the Processing concerned;

1.2     “Data Transfer” shall mean any transfer of Personal Data to a person, entity or service of any kind
        located in a third country that does not benefit from an adequacy decision of the European Commission
        within the meaning of Article 45 of the GDPR, and/or any access to Personal Data by a person, entity
        or service of any kind located in such country.

1.3     “Processing”: shall mean the processing of Personal Data within the meaning of the GDPR, entrusted
        to La Growth Machine, limited to those described in Article 3.

Article 2    PURPOSE

The purpose of the DPA is to define the terms and conditions applicable to the Processing implemented in the
course of the Services. This Processing is related to the use by the Client of La Growth Machine.
Article 3    LIST OF PROCESSING IMPLEMENTED

In the course of the Services, the following Processing may take place:

 N°    Purpose                 Data Subjects                  Qualification of La   Qualification of Client
                                                              Growth Machine

 1     Collection       and    Natural persons meeting        Data Processor        Data Controller
       extraction         of   the criteria defined by
       Personal        Data    the Client within La
       available    through    Growth Machine.
       the         LinkedIn
       account of the Client

 2     Collection       and    Natural persons meeting        Data Processor        Data Controller
       extraction         of   the criteria defined by
       Personal Data freely    the Client within La
       available on Internet   Growth Machine.

 3     Collection through      Natural persons meeting        Data Processor        Data Controller
       internal third-party    the criteria defined by
       tools used by the       the Client within La
       Client.                 Growth Machine.

 4     Export personal data    Natural persons meeting        Data Processor        Data Controller
       to third-party tools    the criteria defined by
       used and designated     the Client within La
       by the Client.          Growth Machine.

 5     Automatic sending       Natural persons meeting        Data Processor        Data Controller
       of        commercial    the criteria defined by
       prospecting             the Client within La
       messages via the        Growth Machine.
       Client account.

 6     Operation     and       Users.                         Data Controller       Data Controller
       management of user
       accounts

 7     Support,                Users.                         Data Controller       N/A
       maintenance      and
       improvement             Natural persons meeting
       operations              the criteria defined by
                               the Client within La
                               Growth Machine.

 8     Contract                Natural           persons      Data Controller       N/A
       management              identified     in     the
                               Agreement          and/or
                               designated by the Client
                               as points of contact.

Article 4    DESCRIPTION AND METHODS OF PROCESSING CARRIED OUT

For the sole purpose of the performance of the Services, the Client - as Data Controller - authorizes La Growth
Machine - as Data Processor - to carry out the Processing on his behalf, the modalities of which are more
precisely                    described                    in                    Appendix                      A
Description and modalities of the processing. The Subprocessors are listed in Appendix B
Sub processors list.

                                                     2 / 14
Article 5      OBLIGATIONS OF THE PARTIES

5.1       Obligations of each Party

Each of the Parties undertakes to comply with all the legal obligations imposed on it pursuant to the Data
Protection Law on the Protection of Personal Data.

5.2       Obligations of the Client

As the person responsible for the Processing, the represents and warrants the Processing implemented is/are:

      (i) carried out in a fair and lawful manner;
      (ii) carried out for specific, explicit and legitimate purposes;
      (iii) strictly limited to Personal Data that is (a) adequate, relevant and not excessive in relation to the
            purposes of the Processing, (b) accurate, complete and, where applicable, up to date;
      (iv) on an adequate legal basis within the meaning of the GDPR.
In addition, the Client undertakes to comply with its obligation to inform the Data Subjects.

5.3       Obligations of La Growth Machine

5.3.1     Processing on documented instructions from the Client

La Growth Machine undertakes to process Personal Data solely upon documented instructions of the Client,
including in relation to Data Transfers

Notwithstanding the foregoing, La Growth Machine may proceed with any other processing when required by
the European authorities or the applicable law to which it is subject. In such a situation, La Growth Machine
undertakes to inform the Client of this obligation to process Personal Data, before proceeding with this
Processing, unless the relevant law limits such information.

The Parties expressly agree that the DPA, as well as the Terms of Services, constitute documented instructions
from the Client in the sense of the previous paragraph.

5.3.2     Assistance provided for the Client

In accordance with the Data Protection Law on the Protection of Personal Data, La Growth Machine undertakes
to fulfill its obligation(s):
      (i) to assist the Client in responding to requests to exercise the rights of the Data Subjects and to comply,
          where appropriate, with such requests;
      (ii) relating to the security of the Processing implemented and the confidentiality of the Personal Data
           collected and processed;
      (iii) to notify Personal Data Breaches;
      (iv) to carry out prior impact studies and to consult, where necessary, the Supervisory Authorities prior to
           the implementation of a Processing.
5.3.3     Processing’s security

La Growth Machine commits itself to take and maintain all appropriate technical and organizational measures
with regard to the risks presented by the concerned Processing in order to ensure an adequate level of security
of the concerned Processing and to protect the Personal Data collected and processed in the framework of
the implementation of said Processing.

5.3.4     Confidentiality of Personal Data

La Growth Machine undertakes to implement procedures to ensure that any third party to whom it allows
access, to the extent permitted by the DPA, to the relevant Personal Data, including its employees,
subcontractors, and other partners, is bound by appropriate obligations of confidentiality in relation to the
relevant Personal Data.

                                                         3 / 14
5.3.5   Right to audit

Within the limit of one (1) per year, the Client may carry out or have carried out, at his own expense, an audit
of La Growth Machine in order to ensure that the latter complies with the stipulations of the DPA, in the
situation where the Client notices that La Growth Machine does not comply with its commitments.

If the Client wishes to call upon a third party to carry out the audit, this third party shall not be a competitor
of La Growth Machine and shall (i) be subject to confidentiality obligations at least as restrictive as those
mentioned in the DPA or in the Terms of Services; and (ii) respect the hygiene and security measures of La
Growth Machine. The Client vouches for that its auditors to comply with the provisions of this article.

The Client shall notify La Growth Machine in writing, with a minimum of fifteen (15) working days beforehand,
of its decision to proceed with an audit, specifying its scope and its methods. The Client will try to conduct the
audits in such a way as to cause the minimum of disturbances and interruptions to the activities of La Growth
Machine. The audits can only be conducted during the working hours of La Growth Machine’s offices. La
Growth Machine will endeavor to cooperate in the audit. If the duration and/or conduct of the audit affects
the activities of La Growth Machine by extending beyond one (1) day, La Growth Machine may charge the
Client for the costs incurred by La Growth Machine on the basis of the time spent by its employees and/or
service providers to participate in the audit. If the audit affects the provision of the services, La Growth Machine
will not be liable for any credit or responsibility whatsoever.

The audit can only concern the last twelve (12) months of activity before the beginning of the audit. During
the audit, the Client will not have access to (i) data or information about other clients and prospects of La
Growth Machine; (ii) any internal data that La Growth Machine considers to be proprietary (e.g., cost structure,
financial data, accounting information); or (iii) any other Confidential Information of La Growth Machine that
is not directly and strictly relevant to the purpose of the audit.

All information disclosed or exchanged in the course of conducting an audit, as well as the results thereof,
constitutes Confidential Information.

5.3.6   Subcontracting

La Growth Machine can call upon any sub-processor to carry out specific processing activities. In this case, it
shall inform the Client in advance and in writing of any changes envisaged concerning the addition or
replacement of other sub-processors.

The sub-Processor is obliged to comply with the obligations hereunder on behalf of and on instructions from
the Client. It is the La Growth Machine responsibility to ensure that the sub-processor provides the same
sufficient guarantees to implement appropriate technical and organizational measures in such a manner that
processing meets the requirements of the GDPR. Where the sub-processor fails to fulfill its data protection
obligations, La Growth Machine remains fully liable with regard to the Client for the sub-processor’s
performance of its obligations.

The Client has a maximum of seven (7) days from the date of receipt of this information to present its
objections under the conditions set forth in the Terms of Services. In the event that no agreement can be
reached on the identity of the subsequent sub-processor to be recruited, and performance of the Agreement
cannot be pursued as a result, the Client shall have the right to terminate the Terms of Services.

5.3.7   Deletion/restitution of Personal Data

La Growth Machine undertakes, at the end of the Terms of Services, to proceed to the definitive and irreversible
deletion of all the Personal Data still in its possession or to return all the Personal Data to the Client.

In the absence of documented instructions from the Client, La Growth Machine will prioritize the deletion of
the Personal Data concerned, according to the previous paragraph.

5.3.8   Duty to inform

In case La Growth Machine considers that a documented instruction of the Client concerning the entrusted
Processing could be considered as illicit with regard to the Data Protection Law or could lead to a breach or
violation of the latter, La Growth Machine undertakes to inform the Client.

                                                       4 / 14
In the event of a Personal Data Breach, La Growth Machine will (i) inform the Client within a reasonable delay
after being aware of the Personal Data Breach, in order to provide the Client with all relevant information; and
(ii) update the Client regarding any remediation action implemented in order to correct the Personal Data
Breach and mitigate the associated risks; and (iii) provide the Client with any reasonable assistance it may
require while handling such Personal Data Breach, as the case may be under conditions agreed upon between
the Parties.

5.3.9   Data Protection Officer

La Growth Machine has appointed a Data Protection Officer (“DPO”) who can be contacted by e-mail at the
following address privacy@lagrowthmachine.com. The DPO is the Client’s main contact for any questions
relating to the personal data protection.

Article 6    PREVALENCE

In the event of a conflict between the provisions of the DPA and the Terms of Services, the Parties agree that
the former shall prevail.

                                                     5 / 14
                                              APPENDIX A
                            DESCRIPTION AND MODALITIES OF THE PROCESSING

1.   PROCESSING N°1

 Purposes of the Processing      Enable the Client to proceed with automated prospecting campaigns

 Collection of the data          La Growth Machine collects LinkedIn data at the client's request and
                                 through its LinkedIn account

 List of Data Subjects           Natural persons holding a position within a prospect of the Client

 List of the Personal Data Name, first name(s), business e-mail address, occupation, previous
 concerned                 professional experiences, phone number (when available), date of birth
                           (when available), geographical position (when available), profile picture
                           (when available), biography, sent and received messages on relevant
                           channels (e.g., LinkedIn, X, e-mail)

 List of special categories of N/A
 Personal Data concerned

 Means of data collection        La Growth Machine platform

 Exhaustive    list   of   sub- MongoDB; Scaleway; Amazon Web Services; Bright Data; Macstadium;
 processors                     Microsoft; Google

 Data Transfer                   Yes (Appendix B)

 Retention period                3 years from collection

 Fate of the Personal Data Definitive deletion
 concerned at the end of the
 Terms of Services

2.   PROCESSING N°2

 Purposes of the Processing      Enable the Client to proceed with automated prospecting campaigns

 Collection of the data          La Growth Machine collects data of Data Subjects at the Client's request
                                 and through various websites, when the data is freely available.

 List of Data Subjects           Natural persons meeting the profile sought by the Client

                                                  6 / 14
 List of the Personal Data Name, first name(s), business e-mail address, occupation, previous
 concerned                 professional experiences, phone number (when available), date of birth
                           (when available), geographical position (when available), profile picture
                           (when available), biography.

 List of special categories of N/A
 Personal Data concerned

 Means of data collection        La Growth Machine platform

 Exhaustive    list   of   sub- MongoDB; Scaleway; Amazon Web Services; Bright Data
 processors

 Data Transfer                   Yes

 Retention period                3 years from collection

 Fate of the Personal Data Definitive deletion
 concerned at the end of the
 Terms of Services

3.   PROCESSING N°3

 Purposes of the Processing      Enable the Client to proceed with automated prospecting campaigns

 Collection of the data          La Growth Machine collects data at the client's request and through
                                 internal third-party tools used by the Client.

 List of Data Subjects           Natural persons holding a position within a prospect of the Client

 List of the Personal Data Name, first name(s), business e-mail address, occupation, previous
 concerned                 professional experiences, phone number (when available), date of birth
                           (when available), geographical position (when available), profile picture
                           (when available), biography, sent and received messages on relevant
                           channels (e.g., LinkedIn, X, e-mail)

 List of special categories of N/A
 Personal Data concerned

 Means of data collection        La Growth Machine platform

 Exhaustive    list   of   sub- MongoDB; Scaleway; Amazon Web Services; Bright Data; Macstadium,
 processors                     Microsoft, Google;

 Data Transfer                   Yes (Appendix B)

                                                  7 / 14
 Retention period                3 years from collection

 Fate of the Personal Data Definitive deletion
 concerned at the end of the
 Terms of Services

4.   PROCESSING N°4

 Purposes of the Processing      Enable the Client to proceed with automated prospecting campaigns

 Collection of the data          La Growth Machine collects data at the client's request in order to export
                                 personal data to third-party tools used and designated by the Client.

 List of Data Subjects           Natural persons holding a position within a prospect of the Client

 List of the Personal Data Name, first name(s), business e-mail address, occupation, previous
 concerned                 professional experiences, phone number (when available), date of birth
                           (when available), geographical position (when available), profile picture
                           (when available), biography, sent and received messages on relevant
                           channels (e.g., LinkedIn, X, e-mail)

 List of special categories of N/A
 Personal Data concerned

 Means of data collection        La Growth Machine platform

 Exhaustive    list   of   sub- MongoDB; Scaleway; Amazon Web Services; Bright Data; Macstadium,
 processors                     Microsoft, Google;

 Data Transfer                   Yes (Appendix B)

 Retention period                3 years from collection

 Fate of the Personal Data Definitive deletion
 concerned at the end of the
 Terms of Services

5.   PROCESSING N°5

 Purposes of the                 Sending automatic messages to the Data Subjects.
 Processing

 Collection of the data          La Growth Machine collects data of Data Subjects at the Client's request
                                 and through various websites in order to enrich its data base.

                                                  8 / 14
 List of Data Subjects           Natural persons holding a position within a prospect of the Client.

 List of the Personal Data       Name, first name(s), business e-mail address, occupation, previous
 concerned                       professional experiences, phone number (when available), date of birth
                                 (when available), geographical position (when available), profile picture
                                 (when available), biography.

 List of special categories of   N/A
 Personal Data concerned

 Means of data collection        La Growth Machine Platform

 Exhaustive list of Sub-         Amazon Web Services; Google Suite; Drop contact; Genderapi; OpenAI.
 processors

 Data Transfer                   Yes

 Retention period                3 years from collection

 Fate of the Data concerned      Definitive deletion
 at the end of the Terms of
 Services

6.   PROCESSING N°6

 Purposes of the                 Operation and management of user accounts
 Processing

 Collection of the data          La Growth Machine collects data of Data Subjects from the Client.

 List of Data Subjects           Natural persons holding a position within the Client.

 List of the Personal Data       Name, first name(s), business e-mail address, occupation, geographical
 concerned                       position (when available), profile picture (when available).

 List of special categories of   N/A
 Personal Data concerned

 Means of data collection        La Growth Machine Platform

 Exhaustive list of Sub-         Amazon Web Services; Google Suite; OpenAI, MongoDB, Stripe,
 processors                      Intercom.

 Data Transfer                   Yes

                                                  9 / 14
 Retention period                Duration of the Subscription Plan.

 Fate of the Data concerned      Definitive deletion of personal data (anonymous usage data are kept)
 at the end of the Terms of
 Services

7.   PROCESSING N°7

 Purposes of the                 Support, maintenance and improvement operations
 Processing

 Collection of the data          La Growth Machine collects data of Data Subjects from the Client.

 List of Data Subjects           Natural persons holding a position within the Client.

 List of the Personal Data       Name, first name(s), business e-mail address, occupation, geographical
 concerned                       position (when available), profile picture (when available), use of
                                 Services and Software.

 List of special categories of   N/A
 Personal Data concerned

 Means of data collection        La Growth Machine Platform

 Exhaustive list of Sub-         Amazon Web Services; Google Suite; OpenAI, Intercom.
 processors

 Data Transfer                   Yes

 Retention period                Duration of the Subscription Plan.

 Fate of the Data concerned      Definitive deletion of personal data (anonymous usage data are kept).
 at the end of the Terms of
 Services

8.   PROCESSING N°8

 Purposes of the                 Contract management
 Processing

 Collection of the data          La Growth Machine collects data of Data Subjects from the Client.

 List of Data Subjects           Natural persons holding a position within the Client.

                                                 10 / 14
List of the Personal Data       Name, first name(s), business e-mail address, occupation.
concerned

List of special categories of   N/A
Personal Data concerned

Means of data collection        La Growth Machine Platform

Exhaustive list of Sub-         Amazon Web Services; Google Suite, MongoDB, Stripe, Intercom
processors

Data Transfer                   Yes

Retention period                One (1) year after expiry or termination of the Agreement

Fate of the Data concerned      Archival for legal reasons.
at the end of the Terms of
Services

                                                 11 / 14
                                            APPENDIX B
                                        SUB PROCESSORS LIST

  Name of            Processing            Data Transfer               Country                Transfer
Subprocessor                                                                                  warranty
                                             Outside EU

MongoDB        Platform operation,        Yes                 Processing: Ireland           MongoDB use
               enrichment of the data                                                       standard
               base                                           Head office: New-York         contractual
                                                                                            clauses and
                                                                                            have a
                                                                                            certification to
                                                                                            the EU-US
                                                                                            Data Privacy
                                                                                            Framework,
                                                                                            the US
                                                                                            Extension to
                                                                                            the EU-US
                                                                                            DPF, and the
                                                                                            Swiss US DPF.

Scaleway       Platform operation         N/A                 Processing : France           N/A

                                                              Head office: 8, rue de la
                                                              Ville de l’Evêque, 75008,
                                                              Paris France

Amazon Web     Platform operation,        N/A                 Processing: France /          N/A
Services       maintenance, support,                          Luxembourg

                                                              Head office: 31 place des
                                                              Corolles, Tour Carpe Diem,
                                                              92400,         Courbevoie,
                                                              France.

Bright Data    Platform operation         N/A                 Processing: Israel            N/A

                                                              Head       office:    4
                                                              Hamachshev St.; Netanya
                                                              4250713; Israel

Macstadium     Platform operation,        N/A                 Processing: Ireland           N/A
               LinkedIn automation
                                                              Head office 3525 Piedmont
                                                              Road, NE, Building 7, Suite
                                                              700, Atlanta, GA 30305.

Google Suite   Client communication,      N/A                 Processing: France            N/A
               reporting, analysis,
               technical improvement                          Head office:8, rue de
                                                              Londres, 75009, Paris,
                                                              France

Drop Contact   E-mail enrichment on       N/A                 Processing: France            N/A
               Client’s instructions
                                                              Head office: 7, place de
                                                              l’Hôtel de Ville, 93600,

                                                12 / 14
                                                      Aulnay-sous-Bois, France.

Genderapi   Gender enrichment on     N/A              Processing: Germany           N/A
            Client’s instructions
                                                      Head office: Markus Perl IT
                                                      Solutions    -   Hermann-
                                                      Mayrhofer-Str. 3 - 94036
                                                      Passau - Germany

OpenAI      Platform operation; e-   Yes (Residual)   Processing: European          Use standard
            mail prospection:                         Union                         contractual
            automatically suggest                                                   clauses.
            messages to be sent.                      Head office: 548 Market
                                                      Street; PMB 97273; San
                                                      Francisco,      California
                                                      94104-5401; United States

Microsoft   Platform operation,      Yes (Residual)   Processing: France            Implemented
            LinkedIn automation                                                     relevant
                                                      Head office: 37 Quai du       contractual
                                                      Président Roosevelt,          undertakings
                                                      92130 Issy-les-Moulineaux

Stripe      Platform operation;      N/A              Processing: Ireland
            payment processor
                                                      Head office:
                                                      1 Grand Canal Street Lower,
                                                      Grand Canal Dock,
                                                      Dublin D02 H210, Ireland

Intercom    Platform operation,      Yes (Residual)   Processing: Ireland
            support operation
                                                      Head office: 55 2nd
                                                      Street, 4th Floor,

                                                      San Francisco, CA 94105;
                                                      United States

                                           13 / 14
                                                 APPENDIX C
                                             SECURITY MEASURES

All treated information is protected in transit using the HTTPS protocol.

All servers are located in the EU in order to be fully GDPR compliant.

All the backups are encrypted usingAES 256. In order to ensure a high availability of our service, we track
everything with alert monitoring tools that contacts the development team in case of failure. Our uptime can
be consulted here : https://status.lagrowthmachine.com/

Our web hosts (MongoDB, AWS and Scaleway) are certified by leading third-party cybersecurity auditors.

Databases are built with multi-layer security including encrypted passwords, 2FA, intrusion detection systems,
and VPC with strict firewall settings.

Integrated SaaS Services are authorized securely with OAuth2 and credentials are not stored for those services.

Our IT infrastructure is replicated via AWS High Availability which guarantees zero downtime.

Automatic data backup is performed several times a day, with a maximum 24-hour RTO and RPO.

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