Data Processing Agreement

This EU and UK Data Processing Contract (the "Contract") supplements the Terms of Service (the "TOS") entered into by and between the customer signing this Contract ("Client") and Vocations ("Organization").

By executing the Contract, Client enters into this Contract on behalf of itself and, to the extent required under applicable Data Protection Laws (defined below).

This Contract incorporates the terms of the TOS, and any terms not defined in this Contract will have the meaning set forth in the TOS.

1. Definitions

"Authorized Sub-Processor" means a third-party who has a need to know or otherwise access Client's Personal Data to enable Organization to perform its responsibilities under this Contract or the TOS.

"Client Account Data" means personal information that relates to Client's relationship with Organization, including the names or contact information of individuals authorized by Client to access Client's account and billing information of individuals that Client has associated with its account. Client Account Data also includes any information Organization may need to collect for the purpose of managing its relationship with Client, identity verification, or as otherwise required by applicable laws and regulations.

"Client Usage Data" means Service usage information collected and handled by Organization in connection with the provision of the Services, such as information used to identify the source and destination of a communication, activity logs, and information used to optimize and maintain performance of the Services, and to investigate and prevent system abuse.

"Client Leads Data" means personal information that Client provides to Organization in connection with the Services or personal information collected by the Client within the Services, such as names, email addresses, phone numbers, and other contact information of Client's prospects.

"Data Protection Laws" means any applicable laws and regulations in any relevant jurisdiction relating to the use or handling of Personal Data, for the geography of our service the General Data Protection Regulation (Regulation (EU) 2016/679) ("EU GDPR" or "GDPR").

"EU SCCs" means the standard contractual clauses approved by the European Commission in Commission Decision 2021/914 dated 4 June 2021, for transfers of personal information to countries not otherwise recognized as offering an adequate level of protection for personal information by the European Commission (as amended and updated from time to time).

"ex-EEA Transfer" means the transfer of Personal Data, which is handled following the GDPR, from the Data Exporter to the Data Importer (or its premises) outside the European Economic Area (the "EEA"), and such transfer is not governed by an adequacy decision made by the European Commission following the relevant provisions of the GDPR.

"Profile Data" means Personal Data collected and handled by the Organization from public web pages using the Organization robot for provision of the Services.

"Services" will have the meaning set forth in the TOS.

"Standard Contractual Clauses" means the EU SCCs and the International Data Transfer Addendum to the EU SCCs issued by the Information Commissioner's Office dated March 21 2022.

2. Relationship between the Parties; Processing of Data

2.1 The parties acknowledge and agree that with regard to the handling of Personal Data, Client may act either as a controller or handler and, except as expressly set forth in this Contract or the TOS, Organization is a handler. Client instructs the Organization to handle Personal Data following this Contract, and is responsible for providing all notices and obtaining all consents, licences and legal bases required to allow the Organization to handle Personal Data. Client will ensure that the handling of Personal Data following Client's instructions will not cause Organization to be in breach of the Data Protection Laws. Client will not provide or make available to Organization any Personal Data in violation of the TOS or otherwise inappropriate for the nature of the Services, and will indemnify Organization from all claims and losses in connection therewith.

2.2 Organization will not handle Personal Data (i) for purposes other than those set forth in the TOS and/or Exhibit A, (ii) in a manner inconsistent with the terms and conditions set forth in this Contract or any other documented instructions provided by Client, including with regard to transfers of personal information to a third country or an international organization, unless required to do so by Supervisory Authority to which the Organization is subject; in such a case, the Organization will inform the Client of that legal requirement before handling, unless that law prohibits such information on important grounds of public interest, or (iii) in violation of Data Protection Laws. Client through this instructs Organization to handle Personal Data following the foregoing and as part of any handling initiated by Client in its use of the Services. These instructions will always be documented.

2.3 The subject matter, nature, purpose, and duration of this handling, as well as the types of Personal Data collected and categories of Data Subjects, are described in Exhibit A to this Contract.

2.4 Following completion of the Services, at Client's choice, Organization will delete Client's Personal Data, unless further storage of such Personal Data is required or authorized by applicable law. If Client and Organization have entered into Standard Contractual Clauses as described in Section 6 (Transfers of Personal Data), the parties agree that the certification of deletion of Personal Data that is described in Clause 8.1(d) and Clause 8.5 of the EU SCCs (as applicable) will be provided by Organization to Client only upon Client's request.

2.5 CCPA. Except with respect to Client Account Data and Client Usage Data, the parties acknowledge and agree that Organization is a service provider for the purposes of the CCPA (to the extent it applies) and is receiving personal information from Client in order to provide the Services pursuant to the TOS, which constitutes a business purpose. Organization will not sell any such personal information. Organization will not retain, use or disclose any personal information provided by Client pursuant to the TOS except as required for the specific purpose of performing the Services for Client pursuant to the TOS, or otherwise as set forth in the TOS or as permitted by the CCPA. The terms "personal information," "service provider," "sale," and "sell" are as defined in Section 1798.140 of the CCPA. Organization certifies that it understands the restrictions of this Section 2.5.

3. Confidentiality

Organization will ensure that any person it authorizes to handle Personal Data has agreed to protect Personal Data following Organization's confidentiality responsibilities in the TOS. Client agrees that Organization may disclose Personal Data to its advisers, auditors or other third parties as reasonably required in connection with the performance of its responsibilities under this Contract, the TOS, or the provision of Services to Client.

4. Authorized Sub-Processors

4.1 Client acknowledges and agrees that Organization may (1) engage the Authorized Sub-Processors on the List (defined below) to access and handle Personal Data in connection with the Services and (2) from time to time engage additional third parties for the purpose of providing the Services, including the handling of Personal Data. By way of this Contract, Client provides general written authorization to Organization to engage sub-handlers as required to perform the Services.

4.2 A list of Organization's current Authorized Sub-Processors (the "List") will be made available to Client. Such List may be updated by Organization from time to time. Organization will provide a mechanism to subscribe to notifications (which may include but are not limited to email) of new Authorized Sub-Processors at least fourteen (14) days before enabling any third party other than existing Authorized Sub-Processors to access or participate in the handling of Personal Data; Organization will add such third party to the List and notify Client, via the aforementioned notifications. Client may object to such an engagement by informing Organization in writing within seven (7) days of receipt of the aforementioned notice by Client, provided such objection is in writing and based on reasonable grounds relating to information protection. Client acknowledges that certain sub-handlers are essential to providing the Services and that objecting to the use of a sub-handler may prevent Organization from offering the Services to Client.

4.3 If Client reasonably objects to an engagement following Section 4.2, and Organization cannot provide a commercially reasonable alternative within a reasonable period of time, Client may discontinue the use of the affected Service by providing written notice to Organization. Discontinuation will not relieve Client of any fees owed to Organization under the TOS.

4.4 If Client does not object to the engagement of a third party following Section 4.2 within seven (7) days of notice by Organization, that third party will be deemed an Authorized Sub-Processor for the purposes of this Contract.

4.5 Organization will enter into a written agreement with the Authorized Sub-Processor imposing on the Authorized Sub-Processor information protection responsibilities comparable to those imposed on Organization under this Contract with respect to the protection of Personal Data. In case an Authorized Sub-Processor fails to fulfill its information protection responsibilities under such written agreement with Organization, Organization will remain liable to Client for the performance of the Authorized Sub-Processor's responsibilities under such agreement.

4.6 If Client and Organization have entered into Standard Contractual Clauses as described in Section 6 (Transfers of Personal Data), (i) the above authorizations will constitute Client's prior written consent to the subcontracting by Organization of the handling of Personal Data if such consent is required under the Standard Contractual Clauses, and (ii) the parties agree that the copies of the agreements with Authorized Sub-Processors that must be provided by Organization to Client pursuant to Clause 9(c) of the EU SCCs may have commercial information, or information unrelated to the Standard Contractual Clauses or their equivalent, removed by the Organization beforehand, and that such copies will be provided by the Organization only upon request by Client.

4.7 Organization will agree a third party beneficiary clause with the Authorized Sub-Processor whereby — in the event Organization has factually disappeared, ceased to exist in law or has become insolvent — Client will have the right to terminate the Authorized Sub-Processor contract and to instruct the Authorized Sub-Processor to erase or return the personal information.

5. Security of Personal Data

5.1 Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of handling as well as the risk of varying likelihood and severity for the entitlements and liberties of natural persons, Organization will maintain appropriate technical and organizational measures to ensure a level of security appropriate to the risk of handling Personal Data. This includes protecting the information against a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access to the information (personal information breach). In assessing the appropriate level of security, the Parties will take due account of the state of the art, the costs of implementation, the nature, scope, context and purposes of handling and the risks involved for the information subjects. Exhibit B sets forth additional information about the Organization's technical and organizational security measures.

6. Transfers of Personal Data

6.1 The parties agree that the Organization may transfer Personal Data handled under this Contract outside the EEA, the UK, or Switzerland as required to provide the Services. Client acknowledges that Organization's primary handling operations take place in the European Union, however, the Organization may engage Sub-Processors based in the United States as listed in clause 4.2, in which case appropriate contractual safeguards will be implemented to ensure compliance with Data Protection Laws. If Organization transfers Personal Data protected under this Contract to a jurisdiction for which the European Commission has not issued an adequacy decision, Organization will ensure that appropriate safeguards have been implemented for the transfer of Personal Data following Data Protection Laws.

6.2 Ex-EEA Transfers. The parties agree that ex-EEA Transfers are made pursuant to the EU SCCs, which are deemed entered into (and incorporated into this Contract by this reference) and completed as follows:

6.2.1 Module One (Controller to Controller) of the EU SCCs apply when Organization is handling Personal Data as a controller pursuant to Section 10 of this Contract.

6.2.2 Module Two (Controller to Processor) of the EU SCCs apply when Client is a controller and Organization is handling Personal Data for Client as a handler pursuant to Section 2 of this Contract.

6.2.3 Module Three (Processor to Sub-Processor) of the EU SCCs apply when Client is a handler and Organization is handling Personal Data on behalf of Client as a sub-handler.

6.3 For each module, where applicable the following applies:

6.3.1 The optional docking clause in Clause 7 does not apply.

6.3.2 In Clause 9, Option 2 (general written authorization) applies, and the minimum time period for prior notice of sub-handler changes will be as set forth in Section 4.2 of this Contract;

6.3.3 In Clause 11, the optional language does not apply;

6.3.4 All square brackets in Clause 13 are hereby removed. The applicable provisions will be the one corresponding to the situation of the information exporter described in square brackets;

6.3.5 In Clause 17 (Option 1), the EU SCCs will be governed by French law;

6.3.6 In Clause 18(b), disputes will be resolved before the courts of France;

6.3.7 Exhibit B to this Contract contains the information required in Annex I of the EU SCCs;

6.3.8 Exhibit C to this Contract contains the information required in Annex II of the EU SCCs; and

6.3.9 By entering into this Contract, the parties are deemed to have signed the EU SCCs incorporated herein, including their Annexes.

6.4 Ex-UK Transfers. The parties agree that ex-UK Transfers are made pursuant to the EU SCCs and the International Data Transfer Addendum to the EU SCCs, which are deemed entered into and incorporated into this Contract by reference, and completed as follows:

6.4.1 References to the GDPR will be deemed to be references to the UK GDPR and the UK Data Protection Act 2018, references to "supervisory authorities" will be deemed to be references to the UK Information Commissioner, and references to "Member State(s)" or the EU will be deemed to be references to the UK.

6.4.2 The International Data Transfer Addendum to the EU SCCs apply when the Organization handles Client's Personal Data as a handler and involves a transfer which is covered by Chapter V of the UK GDPR.

6.5 Transfers from Switzerland. The parties agree that transfers from Switzerland are made pursuant to the EU SCCs with the following modifications:

6.5.1 The terms "General Data Protection Regulation" or "Regulation (EU) 2016/679" as utilized in the EU SCCs will be interpreted to include the Federal Act on Data Protection of 19 June 1992 (the "FADP," and as revised as of 25 September 2020, the "Revised FADP") with respect to information transfers governed by the FADP.

6.5.2 The terms of the EU SCCs will be interpreted to protect the information of legal entities until the effective date of the Revised FADP.

6.5.3 Clause 13 of the EU SCCs is modified to provide that the Federal Data Protection and Information Commissioner ("FDPIC") of Switzerland will have authority over information transfers governed by the FADP and the appropriate EU supervisory authority will have authority over information transfers governed by the GDPR. Subject to the foregoing, all other requirements of Section 13 will be observed.

6.5.4 The term "EU Member State" as utilized in the EU SCCs will not be interpreted in such a way as to exclude Data Subjects in Switzerland from exercising their rights in their place of habitual residence following Clause 18(c) of the EU SCCs.

6.6 Supplementary Measures. In respect of any ex-EEA Transfer or ex-UK Transfer, the following supplementary measures will apply:

6.6.1 As of the date of this Contract, the Data Importer has not received any formal legal requests from any government intelligence or security service/agencies in the country to which the Personal Data is being exported, for access to (or for copies of) Client's Personal Data ("Government Agency Requests");

6.6.2 If, after the date of this Contract, the Data Importer receives any Government Agency Requests, the Organization will attempt to redirect the law enforcement or government agency to request that information directly from the Client. As part of this effort, Organization may provide Client's basic contact information to the government agency. If compelled to disclose Client's Personal Data to a law enforcement or government agency, Organization will give Client reasonable notice of the demand and cooperate to allow Client to seek a protective order or other appropriate remedy unless Organization is legally prohibited from doing so. Organization will not voluntarily disclose Personal Data to any law enforcement or government agency. Data Exporter and Data Importer will (as soon as reasonably practicable) discuss and determine whether all or any transfers of Personal Data pursuant to this Contract should be suspended in the light of such Government Agency Requests;

6.6.3 The Data Exporter and Data Importer will meet as needed to consider whether: (i) the protection afforded by the laws of the country of the Data Importer to information subjects whose Personal Data is being transferred is sufficient to provide broadly equivalent protection to that afforded in the EEA or the UK, whichever the case may be; (ii) additional measures are reasonably necessary to enable the transfer to be compliant with the Data Protection Laws; and (iii) it is still appropriate for Personal Data to be transferred to the relevant Data Importer, taking into account all relevant information available to the parties, together with guidance provided by the supervisory authorities.

6.6.4 If Data Protection Laws require the Data Exporter to execute the Standard Contractual Clauses applicable to a particular transfer of Personal Data to a Data Importer as a separate agreement, the Data Importer will, on request of the Data Exporter, promptly execute such Standard Contractual Clauses incorporating such amendments as may reasonably be required by the Data Exporter to reflect the applicable appendices and annexes, the details of the transfer and the requirements of the relevant Data Protection Laws.

6.6.5 If either (i) any of the means of legitimizing transfers of Personal Data outside of the EEA or UK set forth in this Contract cease to be valid or (ii) any supervisory authority requires transfers of Personal Data pursuant to those means to be suspended, then Data Importer may by notice to the Data Exporter, with effect from the date set out in such notice, amend or put in place alternative arrangements in respect of such transfers, as required by Data Protection Laws.

7. Rights of Data Subjects

7.1 Organization will, to the extent permitted by law, notify Client upon receipt of a request by a Data Subject to exercise the Data Subject's right of: access, rectification, erasure, information portability, restriction or cessation of handling, withdrawal of consent to handling, and/or objection to being governed by handling that constitutes automated decision-making (such requests individually and collectively "Data Subject Request(s)!"). If Organization receives a Data Subject Request in relation to Client's information, Organization will advise the Data Subject to submit their request to Client and Client will be responsible for responding to such request, including, where necessary, by using the functionality of the Services. Client is solely responsible for ensuring that Data Subject Requests for erasure, restriction or cessation of handling, or withdrawal of consent to handling of any Personal Data are communicated to Organization, and, if applicable, for ensuring that a record of consent to handling is maintained with respect to each Data Subject.

7.2 Organization will, at the request of the Client, and taking into account the nature of the handling applicable to any Data Subject Request, apply appropriate technical and organizational measures to assist Client in complying with Client's obligation to respond to such Data Subject Request and/or in demonstrating such compliance, where possible, provided that (i) Client is itself unable to respond without Organization's assistance and (ii) Organization is able to do so following all applicable laws, rules, and regulations. Client will be responsible to the extent legally permitted for any costs and expenses arising from any such assistance by the Organization.

8. Data Protection Impact Assessments; Audits

8.1 Organization will, taking into account the nature of the handling and the information available to Organization, provide Client with reasonable cooperation and assistance where necessary for Client to comply with its responsibilities under the GDPR to conduct a data protection impact assessment and/or to demonstrate such compliance. Client will be responsible to the extent legally permitted for any costs and expenses arising from any such assistance by the Organization.

8.2 Organization will, taking into account the nature of the handling and the information available to Organization, provide Client with reasonable cooperation and assistance with respect to Client's cooperation and/or prior consultation with any Supervisory Authority, where necessary and where required by the GDPR. Client will be responsible to the extent legally permitted for any costs and expenses arising from any such assistance by the Organization.

8.3 The Organization will maintain records sufficient to demonstrate its compliance with its responsibilities under this Contract. Client will, with reasonable notice to Organization, have the right to review, audit and copy such records at Organization's offices during regular business hours.

8.4 Upon Client's written request at reasonable intervals, and governed by reasonable confidentiality controls, Organization will, either (i) make available for Client's review copies of certifications or reports demonstrating Organization's compliance with prevailing information security standards applicable to the handling of Client's Personal Data, or (ii) if the provision of reports or certifications pursuant to (i) is not reasonably sufficient under Data Protection Laws, allow Client's independent third party representative to conduct an audit or inspection of Organization's information security infrastructure and procedures that is sufficient to demonstrate Organization's compliance with its responsibilities under Data Protection Laws, provided that (a) Client provides reasonable prior written notice of any such request for an audit and such inspection will not be unreasonably disruptive to Organization's business; (b) such audit will only be performed during business hours and occur no more than once per calendar year; and (c) such audit will be restricted to information relevant to Client. Client will be responsible for the costs of any such audits or inspections, such as a reimbursement to Organization for any time expended for on-site audits. If Client and Organization have entered into Standard Contractual Clauses as described in Section 6 (Transfers of Personal Data), the parties agree that the audits described in Clause 8.9 of the EU SCCs will be carried out following this Section 8.4.

8.5 Organization will immediately notify Client if an instruction, in the Organization's opinion, infringes the Data Protection Laws or Supervisory Authority. The parties will make the information referred in Article 8, including the results of any audit, available to the Supervisory Authority on request.

9. Personal Data Breaches

9.1 In the event of a Personal Data Breach, Organization will, without undue delay and no later than 48 hours after having become aware of it, inform Client of the Personal Data Breach and take such steps as Organization in its sole discretion deems necessary and reasonable to remediate such violation (to the extent that remediation is within Organization's reasonable control). In particular, the notification will at least: (i) describe the nature of the personal information breach including where possible, the categories and approximate number of information subjects concerned and the categories and approximate number of personal information records concerned; (ii) communicate the name and contact details of the information protection officer or other contact point where more information can be obtained; (iii) describe the likely consequences of the personal information breach; describe the measures taken or proposed to be taken by the controller to address the personal information breach, including, where appropriate, measures to mitigate its possible adverse effects. Where, and in so far as, it is not possible to provide the information at the same time, the information may be provided in phases without undue further delay.

9.2 In the event of a Personal Data Breach, Organization will, taking into account the nature of the handling and the information available to Organization, provide Client with reasonable cooperation and assistance necessary for Client to comply with its responsibilities under the GDPR with respect to notifying (i) the relevant Supervisory Authority and (ii) Data Subjects affected by such Personal Data Breach without undue delay.

9.3 The responsibilities described in Sections 9.1 and 9.2 will not apply in the event that a Personal Data Breach results from the actions or omissions of Client. Organization's obligation to report or respond to a Personal Data Breach under Sections 9.1 and 9.2 will not be construed as an acknowledgement by Organization of any fault or liability with respect to the Personal Data Breach.

10. Organization's Role as a Controller

10.1 The parties acknowledge and agree that with respect to Profile Data, Client Account Data and Client Usage information, Organization is an independent controller, not a joint controller with Client. The Client obtains Profile Data from the Organization for its own purpose and use, and will be considered a separate and independent Controller with respect to the Profile Data. Each Party is individually and separately responsible for complying with the responsibilities that apply to it as a Data Controller under any applicable Data Protection Laws in relation to the Profile Data.

10.2 Organization will handle Client Account Data and Client Usage Data as a Controller (i) to manage the relationship with Client; (ii) to carry out Organization's core business operations, such as accounting, audits, tax preparation and filing and compliance purposes; (iii) to monitor, investigate, prevent and detect fraud, security incidents and other misuse of the Services, and to prevent harm to Client; (iv) for identity verification purposes; (v) to comply with legal or regulatory responsibilities applicable to the handling and retention of Personal Data to which Organization is subject; and (vi) as otherwise permitted under Data Protection Laws and following this Contract and the TOS. Organization may also handle Client Usage Data as a controller to provide, optimize, and maintain the Services, to the extent permitted by Data Protection Laws. Any handling by the Organization as a controller will be following the Organization's privacy policy.

11. Conflict

In the event of any conflict or inconsistency among the following documents, the order of precedence will be: (1) the applicable terms in the Standard Contractual Clauses; (2) the terms of this Contract; (3) the TOS; and (4) the Organization's privacy policy. Any claims brought in connection with this Contract will be governed by the terms and conditions, including, but not limited to, the exclusions and limitations set forth in the TOS.

12. Non-compliance with this Contract and termination

12.1 Without prejudice to any provisions of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725, in the event that Organization is in breach of its responsibilities under the present Contract, Client may instruct Organization to suspend the handling of personal information until the latter complies with this Contract or the contract is terminated. Organization will promptly inform Client in case it is unable to comply with this Contract, for whatever reason.

12.2 Client will be entitled to terminate this Contract insofar as it concerns handling of personal information following this Contract if: (1) the handling of personal information by Organization has been suspended by the Client pursuant to point (a) and if compliance with this Contract is not restored within a reasonable time and in any event within one month following suspension; (2) Organization is in substantial or persistent breach of this Contract or its responsibilities under Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725; (3) Organization fails to comply with a binding decision of a competent court or the competent Supervisory Authority/ies regarding its responsibilities pursuant to this Contract or to Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

12.3 Organization will be entitled to terminate the contract insofar as it concerns handling of personal information under this Contract where, after having informed Client that its instructions infringe applicable legal requirements, Client insists on compliance with the instructions.

12.4 Following termination of the contract, Organization will, at the choice of Client, delete all personal information handled on behalf of Client and certify to Client that it has done so, or return all the personal information to Client and delete existing copies unless Union or Member State law requires storage of the personal information. Until the information is deleted or returned, Organization will continue to adhere to this Contract.

Exhibit A

Nature and Purpose of Processing

Organization will handle Client's Personal Data as required to provide the Services under the TOS, for the purposes specified in the TOS and this Contract, and following Client's instructions as set forth in this Contract.

Duration of Processing

Organization will handle Client's Personal Data as long as required (i) to provide the Services to Client under the TOS; (ii) for Organization's legitimate business needs; or (iii) as required by applicable law or regulation. Client Account Data, Client Leads Data and Client Usage Data will be handled and stored as set forth in the Organization's Privacy Policy.

Categories of Data Subjects

  • Client's employees, consultants, contractors, and/or agents.
  • Client's professional contacts contained in Client Leads Data.

Categories of Personal Data

Organization handles Personal Data contained in Client Account Data, Client Usage Data, and any Personal Data provided by Client or collected by Organization in order to provide the Services or as otherwise set forth in the TOS or this Contract.

Organization also handles Personal Data contained in Client Leads Data. Categories of Personal Data includes names, email addresses, job titles, phone numbers, and other information contained in Client Leads Data.

Sensitive Data or Special Categories of Data

Clients are prohibited from providing sensitive personal information or special categories of information to Organization, including any information which discloses criminal history.

Exhibit B

The following includes the information required by Annex I and Annex III of the EU SCCs, and Annex 1A and Annex 1B of the International Data Transfer Addendum.

1. The Parties

Data exporter(s)

Name: The party to the Terms of Service with Vocations or its Affiliate (as applicable). Address: The Data Exporter's address. Contact person's name, position and contact details: The name, position and contact details provided by the Data Exporter. Activities relevant to the information transferred under these Clauses: As described in Section 2 of the TOS. Signature and date: By using the Services to transfer Personal Data to the Data Importer, the Data Exporter will be deemed to have signed this Exhibit B. Role (controller/handler): Controller

Data importer(s)

Name: Vocations S.R.L. Address: Via Milano 37/C, Gorgonzola (MI), 20064, Italy. Activities relevant to the information transferred under these Clauses: As described in Section 2 of the TOS. Signature and date: The information importer will be deemed to have signed this Exhibit B on the transfer of Personal Data by the Data Exporter in connection with the Services. Role (controller/handler): Processor

2. Description of the Transfer

Data SubjectsThe data exporter may submit personal data to the data importer through its software, services, systems, products, and/or technologies, the extent of which is determined and controlled by the data exporter in compliance with applicable data protection laws and regulations, and which may include but is not limited to personal data relating to the following categories of data subjects: Data Exporter's employees, consultants, contractors, and/or agents.
Categories of Personal DataThe personal data transferred concern the following categories of data: Any personal data composed of all data and information submitted by Data Exporter to Data Importer's software, services, systems, products, and/or technologies, which may include name, contact information, and information about use of Vocations' Services.
Special Category Personal Data (if applicable)Data Exporters are prohibited from providing sensitive data or special categories to Data Importer.
Nature of the ProcessingCompany will process Customer's Personal Data as necessary to provide the Services under the TOS, for the purposes specified in the TOS.
Purposes of ProcessingTo fulfill each party's obligations under the TOS.
Duration of Processing and Retention (or the criteria to determine such period)For the duration of the TOS.
Frequency of the transferFor the duration of the TOS on a periodic basis during the day and/or at the customer's discretion.
Recipients of Personal Data Transferred to the Data ImporterThe company will maintain a list at Sub-Processors.

3. Competent Supervisory Authority

The supervisory authority will be the supervisory authority of the Data Exporter, as determined following Clause 13.

Exhibit C

Description of the Technical and Organizational Security Measures implemented by the Data Importer

The following includes the information required by Annex II of the EU SCCs and Annex 2 of the International Data Transfer Addendum.

Technical and Organizational Security MeasureDetails
Measures for pseudonymization and encryption of personal dataPersonal data is encrypted at rest, using the Advanced Encryption Standard (AES), AES-256. Backups are themselves encrypted or stored on encrypted disks.
Measures to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and servicesThe company's customer contracts contain strict confidentiality obligations. Additionally, the company requires every downstream Sub-Processor to sign confidentiality provisions substantially similar to those contained in the company's customer contracts.
Measures to ensure the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incidentThe database is replicated dynamically. The backup database is stored in a separate infrastructure and encrypted. There are also daily on-site backups.
Processes for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures in order to ensure the security of the processingThe company undergoes an annual security assessment conducted by an independent company. The audit includes a penetration test of the application, an external penetration test of our external perimeter, and a cloud security review of our cloud environment.
Measures for user identification and authorizationThe company has established strong password requirements and verifies that none of the passwords used has been compromised. Users can log in with Google which provides security features such as multi-factor authentication.
Measures for the protection of data during transmissionThe company has implemented secure methods and protocols for the transmission of confidential or sensitive information over public networks. The company uses only recommended secure cipher suites and protocols to encrypt all traffic in transit (e.g. TLS 1.2).
Measures for the protection of data during storageEncryption at rest is automated using AWS-managed disk encryption, which uses industry-standard AES-256 encryption to protect all volume (disk) data.
Measures to ensure physical security of locations at which personal data are processedAll personal data is stored in the Amazon Web Services (AWS) data center in Frankfurt, Germany (eu-central-1). Physical security measures include fences, security patrols, CCTV cameras, thermal cameras, biometric authentication, access badges, metal detectors, and more.
Measures to ensure events loggingAll HTTP requests are logged on AWS. Security log monitoring is managed by the engineering team. Log activities are investigated when necessary and forwarded appropriately.
Measures to ensure system configuration, including default configurationAll production changes are automated through continuous integration and deployment tools to ensure consistent configurations.
Measures for internal IT and IT security governance and managementWe use a strict AWS Identity and Access Management (IAM) policy to ensure administrative access to the infrastructure is limited to individuals who should have access (DevOps/on-call staff).
Measures for certification/assurance of processes and productsThe company undergoes annual security assessments conducted by an independent company.
Measures to ensure data minimizationThe company's Customers unilaterally determine which Personally Identifiable Information (PII) of the Customer they route through the Services. As such, the company operates on a shared responsibility model. The company offers Customers control over exactly which PII data enters the platform. Additionally, the company has integrated self-service features into the Services that allow Customers to delete and suppress PII at their discretion.
Measures to ensure data qualityAll software used to process customer personal data passes through automated testing and a manual pair review before entering production. Data must satisfy both the database schema structure and the format validations defined by the application. There is a QA pipeline for the most critical data, with appropriate alerts in case data is altered.
Measures to ensure limited data retentionThe company's Customers unilaterally determine which Customer Data they route through the Services. As such, the company operates on a shared responsibility model. If a Customer is unable to delete Customer PII via the self-service features of the Services, the company deletes Customer Data upon written request of the Customer, within the time period specified in the Data Processing Agreement and in accordance with the Applicable Data Protection Law.
Measures to ensure accountabilityThe company has taken measures to ensure accountability, such as implementing data protection and information security policies throughout the company, logging and reporting Security Incidents involving Personal Data, and formally assigning roles and responsibilities for information security and data privacy functions. In addition, the company conducts regular third-party audits to ensure compliance with our privacy and security standards.
Measures to allow data portability and ensure erasureAll PII in the Services can be deleted by the Customer or upon the Customer's request.
Technical and organizational measures of sub-processorsThe company enters into Data Processing Agreements with its Authorized Sub-Processors with data protection obligations substantially similar to those contained in this Contract.