Data Processing Agreement

Last updated: August 16, 2019

This Data Processing Agreement (“Agreement“) forms part of the Contract for Services (“Principal Agreement“) between Retention Science (the “Data Processor”), and each of the Data Processor’s customers (the “Company”) (together as the “Parties”).
WHEREAS
(A) The Company acts as a Data Controller.
(B) The Company wishes to subcontract certain Services, which imply the processing of personal data, to the Data Processor.
(C) The Parties seek to implement a data processing agreement that complies with the requirements of the current legal framework in relation to data processing and with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).
(D) The Parties wish to lay down their rights and obligations.

IT IS AGREED AS FOLLOWS:
1. Definitions and Interpretation
1.1 Unless otherwise defined herein, capitalized terms and expressions used in this Agreement shall have the following meaning:
1.1.1 “Agreement” means this Data Processing Agreement and all Schedules;
1.1.2 “Company Personal Data” means any Personal Data Processed by a Contracted Processor on behalf of Company pursuant to or in connection with the Principal Agreement;
1.1.3 “Contracted Processor” means a Subprocessor;
1.1.4 “Data Protection Laws” means EU Data Protection Laws and, to the extent applicable, the data protection or privacy laws of any other country;
1.1.5 “EEA” means the European Economic Area;
1.1.6 “EU Data Protection Laws” means EU Directive 95/46/EC, as transposed into domestic legislation of each Member State and as amended, replaced or superseded from time to time, including by the GDPR and laws implementing or supplementing the GDPR;
1.1.7 “GDPR” means EU General Data Protection Regulation 2016/679;
1.1.8 “Data Transfer” means:
1.1.8.1 a transfer of Company Personal Data from the Company to a Contracted Processor; or
1.1.8.2 an onward transfer of Company Personal Data from a Contracted Processor to a Subcontracted Processor, or between two establishments of a Contracted Processor, in each case, where such transfer would be prohibited by Data Protection Laws (or by the terms of data transfer agreements put in place to address the data transfer restrictions of Data Protection Laws);
1.1.9 “Services” means the services the Company provides.
1.1.10 “Subprocessor” means any person appointed by or on behalf of Processor to process Personal Data on behalf of the Company in connection with the Agreement.

1.2 The terms, “Commission”, “Controller”, “Data Subject”, “Member State”, “Personal Data”, “Personal Data Breach”, “Processing” and “Supervisory Authority” shall have the same meaning as in the GDPR, and their cognate terms shall be construed accordingly.

2. Processing of Company Personal Data

2.1 Details of Data Processing.
2.1.1 Subject matter. The subject matter of the data processing under this DPA is
Customer Data.
2.1.2 Duration. As between Retention Sceince and Customer, the duration of the data processing
under this DPA is determined by Customer.
2.1.3 Purpose. The purpose of the data processing under this DPA is the provision of
the Services initiated by Customer from time to time.
2.1.4 Nature of the processing: Compute, storage and such other Services as described
in the Documentation and initiated by Customer from time to time.
2.1.5 Type of Customer Data: Customer Data uploaded to the Services under
Customer’s Retention Science accounts.
2.1.6 Categories of data subjects: The data subjects may include Customer’s
customers, employees, suppliers and end-users.

2.2 Processor shall:
2.2.1 comply with all applicable Data Protection Laws in the Processing of Company Personal Data; and
2.2.2 not Process Company Personal Data other than on the relevant Company’s documented instructions.
2.3 The Company instructs Processor to process Company Personal Data.

 

3. Processor Personnel
Processor shall take reasonable steps to ensure the reliability of any employee, agent or contractor of any Contracted Processor who may have access to the Company Personal Data, ensuring in each case that access is strictly limited to those individuals who need to know / access the relevant Company Personal Data, as strictly necessary for the purposes of the Principal Agreement, and to comply with Applicable Laws in the context of that individual’s duties to the Contracted Processor, ensuring that all such individuals are subject to confidentiality undertakings or professional or statutory obligations of confidentiality.

4. Security
4.1 Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of Processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, Processor shall in relation to the Company Personal Data implement appropriate technical and organizational measures to ensure a level of security appropriate to that risk, including, as appropriate, the measures referred to in Article 32(1) of the GDPR.
4.2 In assessing the appropriate level of security, Processor shall take account in particular of the risks that are presented by Processing, in particular from a Personal Data Breach.

5. Subprocessing
5.1 Processor shall not appoint (or disclose any Company Personal Data to) any Subprocessor unless required or authorized by the Company.

Sub-processor Obligations. Where Retention Science authorises any sub-processor as described in
Section 5.1:
(i) Retention Science will restrict the sub-processor’s access to Customer Data only to what is
necessary to maintain the Services or to provide the Services to Customer and
any End Users in accordance with the Documentation and Retention Science will prohibit the
sub-processor from accessing Customer Data for any other purpose;
(ii) Retention Science will enter into a written agreement with the sub-processor and, to the
extent that the sub-processor is performing the same data processing services
that are being provided by Retention Science under this DPA, Retention Science will impose on the subprocessor the same contractual obligations that Retention Science has under this DPA; and
(iii) Retention Science will remain responsible for its compliance with the obligations of this DPA
and for any acts or omissions of the sub-processors that cause Retention Science to breach any
of Retention Science’s obligations under this DPA.

6. Data Subject Rights
6.1 Taking into account the nature of the Processing, Processor shall assist the Company by implementing appropriate technical and organizational measures, insofar as this is possible, for the fulfillment of the Company obligations, as reasonably understood by Company, to respond to requests to exercise Data Subject rights under the Data Protection Laws.
6.2 Processor shall:
6.2.1 promptly notify Company if it receives a request from a Data Subject under any Data Protection Law in respect of Company Personal Data; and
6.2.2 ensure that it does not respond to that request except on the documented instructions of Company or as required by Applicable Laws to which the Processor is subject, in which case Processor shall to the extent permitted by Applicable Laws inform Company of that legal requirement before the Contracted Processor responds to the request.

7. Personal Data Breach
7.1 Processor shall notify Company without undue delay upon Processor becoming aware of a Personal Data Breach affecting Company Personal Data, providing Company with sufficient information to allow the Company to meet any obligations to report or inform Data Subjects of the Personal Data Breach under the Data Protection Laws.
7.2 Processor shall co-operate with the Company and take reasonable commercial steps as are directed by Company to assist in the investigation, mitigation and remediation of each such Personal Data Breach.

8. Data Protection Impact Assessment and Prior Consultation Processor shall provide reasonable assistance to the Company with any data protection impact assessments, and prior consultations with Supervising Authorities or other competent data privacy authorities, which Company reasonably considers to be required by article 35 or 36 of the GDPR or equivalent provisions of any other Data Protection Law, in each case solely in relation to Processing of Company Personal Data by, and taking into account the nature of the Processing and information available to, the Contracted Processors.

9. Deletion or return of Company Personal Data
9.1 Subject to this section 9 Processor shall promptly and in any event within 10 business days of the date of cessation of any Services involving the Processing of Company Personal Data (the “Cessation Date”), delete and procure the deletion of all copies of those Company Personal Data.

10. Audit rights
10.1 Subject to this section 10, Processor shall make available to the Company on request all information necessary to demonstrate compliance with this Agreement, and shall allow for and contribute to audits, including inspections, by the Company or an auditor mandated by the Company in relation to the Processing of the Company Personal Data by the Contracted Processors.
10.2 Information and audit rights of the Company only arise under section 10.1 to the extent that the Agreement does not otherwise give them information and audit rights meeting the relevant requirements of Data Protection Law.

11. Data Transfer
11.1 The Processor may not transfer or authorize the transfer of Data to countries outside the EU and/or the European Economic Area (EEA) without the prior written consent of the Company. If personal data processed under this Agreement is transferred from a country within the European Economic Area to a country outside the European Economic Area, the Parties shall ensure that the personal data are adequately protected. To achieve this, the Parties shall, unless agreed otherwise, rely on EU approved standard contractual clauses for the transfer of personal data.

12. General Terms
12.1 Confidentiality. Each Party must keep this Agreement and information it receives about the other Party and its business in connection with this Agreement (“Confidential Information”) confidential and must not use or disclose that Confidential Information without the prior written consent of the other Party except to the extent that:
(a) disclosure is required by law;
(b) the relevant information is already in the public domain.
12.2 Notices. All notices and communications given under this Agreement must be in writing and will be delivered personally, sent by post or sent by email to the address or email address set out in the heading of this Agreement at such other address as notified from time to time by the Parties changing address.

13. Governing Law and Jurisdiction
13.1 This Agreement is governed by the laws of The United States of America.
13.2 Any dispute arising in connection with this Agreement, which the Parties will not be able to resolve amicably, will be submitted to the exclusive jurisdiction of the courts of the United States, subject to possible appeal to the EU.

[1] Parties may reproduce definitions and meanings contained in Directive 95/46/EC within this Clause if they considered it better for the contract to stand alone.

[2] Mandatory requirements of the national legislation applicable to the data importer which do not go beyond what is necessary in a democratic society on the basis of one of the interests listed in Article 13(1) of Directive 95/46/EC, that is, if they constitute a necessary measure to safeguard national security, defense, public security, the prevention, investigation, detection and prosecution of criminal offenses or of breaches of ethics for the regulated professions, an important economic or financial interest of the State or the protection of the data subject or the rights and freedoms of others, are not in contradiction with the standard contractual clauses. Some examples of such mandatory requirements which do not go beyond what is necessary in a democratic society are, inter alia, internationally recognized sanctions, tax-reporting requirements or anti-money-laundering reporting requirements.

[3] This requirement may be satisfied by the sub-processor co-signing the contract entered into between the data exporter and the data importer under this Decision.

Annex 2

Standard Contractual Clauses (processors)
For the purposes of Article 26(2) of Directive 95/46/EC for the transfer of personal data to processors
established in third countries which do not ensure an adequate level of data protection

The entity identified as “Customer” in the DPA
(the “data exporter”)

and

Retention Science
2601 Ocean Park Blvd #104, Santa Monica, CA 90405.
(the “data importer”)

each a “party”; together “the parties”,
HAVE AGREED on the following Contractual Clauses (the Clauses) in order to adduce adequate
safeguards with respect to the protection of privacy and fundamental rights and freedoms of individuals
for the transfer by the data exporter to the data importer of the personal data specified in Appendix 1.
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Clause 1

Definitions
For the purposes of the Clauses:
(a) ‘personal data’, ‘special categories of data’, ‘process/processing’, ‘controller’, ‘processor’, ‘data
subject’ and ‘supervisory authority’ shall have the same meaning as in Directive 95/46/EC of the
European Parliament and of the Council of 24 October 1995 on the protection of individuals with
regard to the processing of personal data and on the free movement of such data;
(b) ‘the data exporter’ means the controller who transfers the personal data;
(c) ‘the data importer’ means the processor who agrees to receive from the data exporter personal
data intended for processing on his behalf after the transfer in accordance with his instructions and
the terms of the Clauses and who is not subject to a third country’s system ensuring adequate
protection within the meaning of Article 25(1) of Directive 95/46/EC;
(d) ‘the subprocessor’ means any processor engaged by the data importer or by any other
subprocessor of the data importer who agrees to receive from the data importer or from any
other subprocessor of the data importer personal data exclusively intended for processing
activities to be carried out on behalf of the data exporter after the transfer in accordance with his
instructions, the terms of the Clauses and the terms of the written subcontract;
(e) ‘the applicable data protection law’ means the legislation protecting the fundamental rights and
freedoms of individuals and, in particular, their right to privacy with respect to the processing of
personal data applicable to a data controller in the Member State in which the data exporter is
established;
(f) ‘technical and organisational security measures’ means those measures aimed at protecting
personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorised
disclosure or access, in particular where the processing involves the transmission of data over a
network, and against all other unlawful forms of processing.

Clause 2

Details of the transfer
The details of the transfer and in particular the special categories of personal data where applicable are
specified in Appendix 1 which forms an integral part of the Clauses.

Clause 3

Third-party beneficiary clause
1. The data subject can enforce against the data exporter this Clause, Clause 4(b) to (i), Clause 5(a)
to (e), and (g) to (j), Clause 6(1) and (2), Clause 7, Clause 8(2), and Clauses 9 to 12 as third-party
beneficiary.
2. The data subject can enforce against the data importer this Clause, Clause 5(a) to (e) and (g),
Clause 6, Clause 7, Clause 8(2), and Clauses 9 to 12, in cases where the data exporter has factually
disappeared or has ceased to exist in law unless any successor entity has assumed the entire legal
obligations of the data exporter by contract or by operation of law, as a result of which it takes on
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the rights and obligations of the data exporter, in which case the data subject can enforce them
against such entity.
3. The data subject can enforce against the subprocessor this Clause, Clause 5(a) to (e) and (g),
Clause 6, Clause 7, Clause 8(2), and Clauses 9 to 12, in cases where both the data exporter and the
data importer have factually disappeared or ceased to exist in law or have become insolvent, unless
any successor entity has assumed the entire legal obligations of the data exporter by contract or by
operation of law as a result of which it takes on the rights and obligations of the data exporter, in
which case the data subject can enforce them against such entity. Such third-party liability of the
subprocessor shall be limited to its own processing operations under the Clauses.
4. The parties do not object to a data subject being represented by an association or other body if
the data subject so expressly wishes and if permitted by national law.

Clause 4

Obligations of the data exporter
The data exporter agrees and warrants:
(a) that the processing, including the transfer itself, of the personal data has been and will continue
to be carried out in accordance with the relevant provisions of the applicable data protection law
(and, where applicable, has been notified to the relevant authorities of the Member State where
the data exporter is established) and does not violate the relevant provisions of that State;
(b) that it has instructed and throughout the duration of the personal data processing services will
instruct the data importer to process the personal data transferred only on the data exporter’s
behalf and in accordance with the applicable data protection law and the Clauses;
(c) that the data importer will provide sufficient guarantees in respect of the technical and
organisational security measures specified in Appendix 2 to this contract;
(d) that after assessment of the requirements of the applicable data protection law, the security
measures are appropriate to protect personal data against accidental or unlawful destruction or
accidental loss, alteration, unauthorised disclosure or access, in particular where the processing
involves the transmission of data over a network, and against all other unlawful forms of processing,
and that these measures ensure a level of security appropriate to the risks presented by the
processing and the nature of the data to be protected having regard to the state of the art and
the cost of their implementation;
(e) that it will ensure compliance with the security measures;
(f) that, if the transfer involves special categories of data, the data subject has been informed or will be
informed before, or as soon as possible after, the transfer that its data could be transmitted to a
third country not providing adequate protection within the meaning of Directive 95/46/EC;
(g) to forward any notification received from the data importer or any subprocessor pursuant to
Clause 5(b) and Clause 8(3) to the data protection supervisory authority if the data exporter
decides to continue the transfer or to lift the suspension;
(h) to make available to the data subjects upon request a copy of the Clauses, with the exception of
Appendix 2, and a summary description of the security measures, as well as a copy of any contract
for subprocessing services which has to be made in accordance with the Clauses, unless the
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Clauses or the contract contain commercial information, in which case it may remove such
commercial information;
(i) that, in the event of subprocessing, the processing activity is carried out in accordance with Clause
11 by a subprocessor providing at least the same level of protection for the personal data and the
rights of data subject as the data importer under the Clauses; and
(j) that it will ensure compliance with Clause 4(a) to (i).

Clause 5

Obligations of the data importer
1 The data importer agrees and warrants:
(a) to process the personal data only on behalf of the data exporter and in compliance with its
instructions and the Clauses; if it cannot provide such compliance for whatever reasons, it agrees
to inform promptly the data exporter of its inability to comply, in which case the data exporter is
entitled to suspend the transfer of data and/or terminate the contract;
(b) that it has no reason to believe that the legislation applicable to it prevents it from fulfilling the
instructions received from the data exporter and its obligations under the contract and that in the
event of a change in this legislation which is likely to have a substantial adverse effect on the
warranties and obligations provided by the Clauses, it will promptly notify the change to the data
exporter as soon as it is aware, in which case the data exporter is entitled to suspend the transfer
of data and/or terminate the contract;
(c) that it has implemented the technical and organisational security measures specified in Appendix
2 before processing the personal data transferred;
(d) that it will promptly notify the data exporter about:
(i) any legally binding request for disclosure of the personal data by a law enforcement
authority unless otherwise prohibited, such as a prohibition under criminal law to
preserve the confidentiality of a law enforcement investigation,
(ii) any accidental or unauthorised access, and
(iii) any request received directly from the data subjects without responding to that request,
unless it has been otherwise authorised to do so;
(e) to deal promptly and properly with all inquiries from the data exporter relating to its processing
of the personal data subject to the transfer and to abide by the advice of the supervisory authority
with regard to the processing of the data transferred;

1 Mandatory requirements of the national legislation applicable to the data importer which do not go beyond
what is necessary in a democratic society on the basis of one of the interests listed in Article 13(1) of Directive
95/46/EC, that is, if they constitute a necessary measure to safeguard national security, defence, public security, the
prevention, investigation, detection and prosecution of criminal offences or of breaches of ethics for the regulated
professions, an important economic or financial interest of the State or the protection of the data subject or the rights
and freedoms of others, are not in contradiction with the standard contractual clauses. Some examples of such
mandatory requirements which do not go beyond what is necessary in a democratic society are, inter alia,
internationally recognised sanctions, tax-reporting requirements or anti-money-laundering reporting requirements.

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(f) at the request of the data exporter to submit its data processing facilities for audit of the processing
activities covered by the Clauses which shall be carried out by the data exporter or an inspection
body composed of independent members and in possession of the required professional
qualifications bound by a duty of confidentiality, selected by the data exporter, where applicable,
in agreement with the supervisory authority;
(g) to make available to the data subject upon request a copy of the Clauses, or any existing contract
for subprocessing, unless the Clauses or contract contain commercial information, in which case it
may remove such commercial information, with the exception of Appendix 2 which shall be
replaced by a summary description of the security measures in those cases where the data subject
is unable to obtain a copy from the data exporter;
(h) that, in the event of subprocessing, it has previously informed the data exporter and obtained its
prior written consent;
(i) that the processing services by the subprocessor will be carried out in accordance with Clause 11;
(j) to send promptly a copy of any subprocessor agreement it concludes under the Clauses to the data
exporter.

Clause 6

Liability
1. The parties agree that any data subject, who has suffered damage as a result of any breach of the
obligations referred to in Clause 3 or in Clause 11 by any party or subprocessor is entitled to receive
compensation from the data exporter for the damage suffered.
2. If a data subject is not able to bring a claim for compensation in accordance with paragraph 1 against
the data exporter, arising out of a breach by the data importer or his subprocessor of any of their
obligations referred to in Clause 3 or in Clause 11, because the data exporter has factually
disappeared or ceased to exist in law or has become insolvent, the data importer agrees that the
data subject may issue a claim against the data importer as if it were the data exporter, unless any
successor entity has assumed the entire legal obligations of the data exporter by contract of by
operation of law, in which case the data subject can enforce its rights against such entity. The data
importer may not rely on a breach by a subprocessor of its obligations in order to avoid its own
liabilities.
3. If a data subject is not able to bring a claim against the data exporter or the data importer referred
to in paragraphs 1 and 2, arising out of a breach by the subprocessor of any of their obligations
referred to in Clause 3 or in Clause 11 because both the data exporter and the data importer have
factually disappeared or ceased to exist in law or have become insolvent, the subprocessor agrees
that the data subject may issue a claim against the data subprocessor with regard to its own
processing operations under the Clauses as if it were the data exporter or the data importer,
unless any successor entity has assumed the entire legal obligations of the data exporter or data
importer by contract or by operation of law, in which case the data subject can enforce its rights
against such entity. The liability of the subprocessor shall be limited to its own processing
operations under the Clauses.

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Clause 7

Mediation and jurisdiction
1. The data importer agrees that if the data subject invokes against it third-party beneficiary rights
and/or claims compensation for damages under the Clauses, the data importer will accept the
decision of the data subject:
(a) to refer the dispute to mediation, by an independent person or, where applicable, by the
supervisory authority;
(b) to refer the dispute to the courts in the Member State in which the data exporter is
established.
2. The parties agree that the choice made by the data subject will not prejudice its substantive or
procedural rights to seek remedies in accordance with other provisions of national or international
law.

Clause 8

Cooperation with supervisory authorities
1. The data exporter agrees to deposit a copy of this contract with the supervisory authority if it so
requests or if such deposit is required under the applicable data protection law.
2. The parties agree that the supervisory authority has the right to conduct an audit of the data
importer, and of any subprocessor, which has the same scope and is subject to the same conditions
as would apply to an audit of the data exporter under the applicable data protection law.
3. The data importer shall promptly inform the data exporter about the existence of legislation
applicable to it or any subprocessor preventing the conduct of an audit of the data importer, or
any subprocessor, pursuant to paragraph 2. In such a case the data exporter shall be entitled to
take the measures foreseen in Clause 5 (b).

Clause 9

Governing Law
The Clauses shall be governed by the law of the Member State in which the data exporter is established.

Clause 10

Variation of the contract
The parties undertake not to vary or modify the Clauses. This does not preclude the parties from adding
clauses on business related issues where required as long as they do not contradict the Clause.

Clause 11

Subprocessing
1. The data importer shall not subcontract any of its processing operations performed on behalf of
the data exporter under the Clauses without the prior written consent of the data exporter.
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Where the data importer subcontracts its obligations under the Clauses, with the consent of the
data exporter, it shall do so only by way of a written agreement with the subprocessor which
imposes the same obligations on the subprocessor as are imposed on the data importer under
the Clauses. Where the subprocessor fails to fulfil its data protection obligations under such
written agreement the data importer shall remain fully liable to the data exporter for the
performance of the subprocessor’s obligations under such agreement.
2. The prior written contract between the data importer and the subprocessor shall also provide for
a third-party beneficiary clause as laid down in Clause 3 for cases where the data subject is not
able to bring the claim for compensation referred to in paragraph 1 of Clause 6 against the data
exporter or the data importer because they have factually disappeared or have ceased to exist in
law or have become insolvent and no successor entity has assumed the entire legal obligations of
the data exporter or data importer by contract or by operation of law. Such third-party liability of
the subprocessor shall be limited to its own processing operations under the Clauses.
3. The provisions relating to data protection aspects for subprocessing of the contract referred to in
paragraph 1 shall be governed by the law of the Member State in which the data exporter is
established.
4. The data exporter shall keep a list of subprocessing agreements concluded under the Clauses and
notified by the data importer pursuant to Clause 5 (j), which shall be updated at least once a year.
The list shall be available to the data exporter’s data protection supervisory authority.

Clause 12

Obligation after the termination of personal data processing services
1. The parties agree that on the termination of the provision of data processing services, the data
importer and the subprocessor shall, at the choice of the data exporter, return all the personal
data transferred and the copies thereof to the data exporter or shall destroy all the personal data
and certify to the data exporter that it has done so, unless legislation imposed upon the data
importer prevents it from returning or destroying all or part of the personal data transferred. In
that case, the data importer warrants that it will guarantee the confidentiality of the personal data
transferred and will not actively process the personal data transferred anymore.
2. The data importer and the subprocessor warrant that upon request of the data exporter and/or
of the supervisory authority, it will submit its data processing facilities for an audit of the measures
referred to in paragraph 1.

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APPENDIX 1 TO THE STANDARD CONTRACTUAL CLAUSES

Data exporter
The data exporter is the entity identified as “Customer” in the DPA

Data importer
The data importer is Amazon Web Services, Inc., a provider of web services.

Data subjects
Data subjects are defined in Section 1.3 of the DPA.

Categories of data
The personal data is defined in Section 1.3 of the DPA.

Processing operations
The personal data transferred will be subject to the following basic processing activities (please specify):
The processing operations are defined in Section 1.3 of the DPA.

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APPENDIX 2 TO THE STANDARD CONTRACTUAL CLAUSES
This Appendix forms part of the Clauses and must be completed by the parties.
Description of the technical and organisational security measures implemented by the data importer in
accordance with Clauses 4(d) and 5(c) (or document/legislation attached):
The technical and organisational security measures implemented by the data importer are as described
in the DPA.

Note: If you would like a version of this DPA that is executable, please submit a request via email to help@retentionscience.com