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Data Processing Addendum

Placeholder. Final document to be provided by counsel before launch.

This Data Processing Addendum ("DPA") forms part of the Terms of Service between the customer ("Controller") and Complarity ("Processor") and governs the processing of personal data on the Controller's behalf.

Subject matter: provision of the Complarity compliance platform. Duration: the term of the underlying subscription. Nature and purpose: hosting, storage, generation of compliance documentation, and audit logging.

Subprocessors: Complarity maintains a current list of subprocessors available on request. Material changes are notified with at least 30 days' notice.

International transfers: no transfer of personal data outside the EEA in the standard configuration. Where a subprocessor operates outside the EEA, Standard Contractual Clauses (Commission Implementing Decision (EU) 2021/914) apply.