Note: You can find our previous terms valid until November 24, 2025 here.

Data Processing Agreement

This Data Processing Addendum (“DPA”) supplements the Dealside Master Subscription Agreement (the “Agreement”) entered into by and between Customer (as defined in the Agreement) and Dealside BV (“Dealside”). 

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By executing the Agreement, Customer enters into this DPA on behalf of itself and, to the extent required under applicable Data Protection Laws (defined below), in the name and on behalf of its Affiliates (defined below), if any. This DPA incorporates the terms of the Agreement, and any terms not defined in this DPA shall have the meaning set forth in the Agreement.

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Section 1. Definitions

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“Authorized Sub-Processor” means a third party who has a need to know or otherwise access Customer’s Personal Data to enable Dealside to perform its obligations under this DPA or the Agreement, and who is either (1) listed in Exhibit B or (2) subsequently authorized under Section 3.2 of this DPA.

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“Customer Account Data” means personal data that relates to Customer business representatives and includes names and contact information, and any other information that is shared generally and necessarily as a result of the actual or potential business relationship between Dealside and the Customer and their respective representatives.

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“Data Exporter” means Customer.

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“Data Importer” means Dealside.

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“Data Protection Laws” means any applicable laws and regulations in any relevant jurisdiction relating to the use or processing of Personal Data including: (i) the California Consumer Privacy Act (“CCPA”), (ii) the General Data Protection Regulation (Regulation (EU) 2016/679) (“EU GDPR” or “GDPR”), (iii) the Swiss Federal Act on Data Protection, (iv) the EU GDPR as it forms part of the law of England and Wales by virtue of section 3 of the European Union (Withdrawal) Act 2018 (the “UK GDPR”); (v) the UK Data Protection Act 2018; and (vi) the Privacy and Electronic Communications (EC Directive) Regulations 2003; in each case, as updated, amended or replaced from time to time. The terms “Data Subject”, “Personal Data”, “Personal Data Breach”, “processing”, “processor”, “controller”, and “supervisory authority” shall have the meanings set forth in the GDPR.

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“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 data to countries not otherwise recognized as offering an adequate level of protection for personal data by the European Commission (as amended and updated from time to time).

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“ex-EEA Transfer” means the transfer of Personal Data, which is processed in accordance with 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 in accordance with the relevant provisions of the GDPR.

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“ex-UK Transfer” means the transfer of Personal Data, which is processed in accordance with the UK GDPR and the Data Protection Act 2018, from the Data Exporter to the Data Importer (or its premises) outside the United Kingdom (the “UK”), and such transfer is not governed by an adequacy decision made by the Secretary of State in accordance with the relevant provisions of the UK GDPR and the Data Protection Act 2018.

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“Services” shall have the meaning set forth in the Agreement.

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“Services” means collectively the Services and the Trial Services, as each defined in the Agreement.

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“UK Addendum” the International Data Transfer Addendum to the Standard Contractual Clauses issued by the Information Commissioner’s Office of the United Kingdom (including all Part 2 Mandatory Clauses).

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Section 2. Relationship of the Parties; Processing of Data

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2.1. Relationship of the Parties. The Parties acknowledge and agree that with regard to the processing of Personal Data, Customer may act either as a controller or processor and, except as expressly set forth in this DPA or the Agreement, Dealside is a processor. Customer shall, in its use of the Services, process Personal Data, and provide instructions for the processing of Personal Data, in compliance with Data Protection Laws. Customer shall ensure that the processing of Personal Data in accordance with Customer’s instructions will not cause Dealside to be in breach of the Data Protection Laws. Customer is solely responsible for the accuracy, quality, and legality of (i) the Personal Data provided to Dealside by or on behalf of Customer, (ii) the means by which Customer acquired any such Personal Data, and (iii) the instructions it provides to Dealside regarding the processing of such Personal Data. Customer shall not provide or make available to Dealside any Personal Data in violation of the Agreement or otherwise inappropriate for the nature of the Services, and shall indemnify Dealside from all claims and losses in connection therewith.

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2.2. Processing Instructions. Dealside shall not process Personal Data (i) for purposes other than those set forth in the Agreement and/or Exhibit A, (ii) in a manner inconsistent with the terms and conditions set forth in this DPA or any other documented instructions provided by Customer, including with regard to transfers of personal data to a third country or an international organization, unless required to do so by Supervisory Authority to which Dealside is subject; in such a case, Dealside shall inform the Customer of that legal requirement before processing, unless that law prohibits such information on important grounds of public interest, or (iii) in violation of Data Protection Laws. Customer hereby instructs Dealside to process Personal Data in accordance with the foregoing and as part of any processing initiated by Customer in its use of the Services.

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

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2.4. Return or Deletion. Following termination of the Agreement, Dealside shall have no right to process Personal Data, except (a) for processing required or authorized by applicable law or (b) as required to facilitate the return or deletion of Personal Data. Customer has the right to request the return or deletion of Personal Data within sixty (60) days after the termination effective date. Personal Data will be deleted from Dealside systems within ninety (90) days after the termination effective date.

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2.5. CCPA. Except with respect to Customer Account Data, the Parties acknowledge and agree that Dealside is a service provider for the purposes of the CCPA (to the extent it applies) and is receiving personal information from Customer in order to provide the Services pursuant to the Agreement, which constitutes a business purpose. Dealside shall not sell any such personal information. Dealside shall not retain, use or disclose any personal information provided by Customer pursuant to the Agreement except as necessary for the specific purpose of performing the Services for Customer pursuant to the Agreement, or otherwise as set forth in the Agreement 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. Dealside certifies that it understands the restrictions of this Section 2.5.

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Section 3. Authorized Sub-Processors

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3.1. Use of Sub-Processors. Customer acknowledges and agrees that Dealside may (1) engage its Affiliates and the Authorized Sub-Processors on the List (defined below) to access and process 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 without limitation the processing of Personal Data. By way of this DPA, Customer provides general written authorization to Dealside to engage sub-processors as necessary to perform the Services.

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3.2. Sub-Processor List. A list of Dealside’s current Authorized Sub-Processors (the “List”) is available to Customer at https://trust.askdonna.com/subprocessors. Such List may be updated from time to time. Dealside will provide a mechanism to subscribe to notifications of new Authorized Sub-Processors at https://trust.askdonna.com (Click on the bell icon in the top right corner of the page, enter your email address and click Subscribe). Customer, if it wishes, will subscribe to such notifications where available. If Customer does not subscribe to such notifications, Customer waives any right it may have to receive prior notice of changes to Authorized Sub-Processors. At least fifteen (15) working days before enabling any third party other than existing Authorized Sub-Processors to access or participate in the processing of Personal Data, Dealside will add such third party to the List and notify subscribers, including Customer, via the aforementioned notifications. Customer may object to such an engagement by informing Dealside in writing within fifteen (15) working days of receipt of the aforementioned notice by Customer, provided such objection is in writing and based on reasonable grounds relating to data protection. Customer acknowledges that certain sub-processors are essential to providing the Services and that objecting to the use of a sub-processor may prevent Dealside from offering the Services to Customer.

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3.3. Objection Procedure. If Customer reasonably objects to an engagement in accordance with Section 3.2, and Dealside cannot provide a commercially reasonable alternative within a reasonable period of time, Customer may discontinue the use of the affected Service by providing written notice to Dealside. Discontinuation shall not relieve Customer of any fees owed to Dealside under the Agreement. If Customer does not object to the engagement of a third party in accordance with Section 3.2, that third party will be deemed an Authorized Sub-Processor for the purposes of this DPA.

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3.5. Sub-Processor Obligations. Dealside will enter into a written agreement with the Authorized Sub-Processor imposing on the Authorized Sub-Processor data protection obligations comparable to those imposed on Dealside under this DPA with respect to the protection of Personal Data. In case an Authorized Sub-Processor fails to fulfill its data protection obligations under such written agreement with Dealside, Dealside will remain liable to Customer for the performance of the Authorized Sub-Processor’s obligations under such agreement.

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3.6. Sub-Processing Under the SCCs. If Customer and Dealside have entered into Standard Contractual Clauses as described in Section 5 (Transfers of Personal Data), (i) the above authorizations will constitute Customer’s prior written consent to the subcontracting by Dealside of the processing 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 Dealside to Customer pursuant to Clause 5(j) of the UK SCCs or Clause 9(c) of the EU SCCs may have commercial information, or information unrelated to the Standard Contractual Clauses or their equivalent, removed by Dealside beforehand, and that such copies will be provided by Dealside only upon request by Customer.

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Section 4. Security of Personal Data

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4.1. Technical and Organizational Measures. 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, Dealside shall maintain appropriate technical and organizational measures to ensure a level of security appropriate to the risk of processing Personal Data. Exhibit C sets forth additional information about Dealside’s technical and organizational security measures.

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4.2. Personal Data Breach Notification. Dealside will notify Customer within forty-eight (48) hours after becoming aware of the unauthorized acquisition, access, use, disclosure or destruction of Customer’s Personal Data, (a “Personal Data Breach”), following determination by Dealside that a Personal Data Breach occurred on its systems. Dealside shall reasonably assist the Customer with the investigation and mitigation of the impact of any such Personal Data Breach as well as any notification obligation towards a supervisory authority that may be necessary.

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4.3. Personal Data Breach Assistance. In the event of a Personal Data Breach, Dealside shall, taking into account the nature of the processing and the information available to Dealside, provide Customer with reasonable cooperation and assistance necessary for Customer to comply with its obligations under Data Protection Laws with respect to notifying (i) the relevant Supervisory Authority and (ii) Data Subjects affected by such Personal Data Breach without undue delay.

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4.4. Disclaimer of Liability. Dealside’s obligation to report or respond to a Personal Data Breach under Sections 4.2 and 4.3 will not be construed as an acknowledgement by Dealside of any fault or liability with respect to the Personal Data Breach.

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Section 5. Transfers of Personal Data

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5.1. Transfers. The Parties agree that Dealside may transfer Personal Data processed under this DPA outside the EEA, the UK, or Switzerland as necessary to provide the Services. If Dealside transfers Personal Data protected under this DPA to a jurisdiction for which the European Commission has not issued an adequacy decision, Dealside will ensure that appropriate safeguards have been implemented for the transfer of Personal Data in accordance with Data Protection Laws.

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5.2. 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 DPA by this reference) and completed as follows:

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5.2.1. Module One (Controller to Controller) of the EU SCCs apply when Dealside is processing Personal Data as a controller pursuant to Section 8 of this DPA.

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5.2.2. Module Two (Controller to Processor) of the EU SCCs apply when Customer is a controller and Dealside is processing Personal Data for Customer as a processor pursuant to Section 2 of this DPA.

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5.2.3. Module Three (Processor to Sub-Processor) of the EU SCCs apply when Customer is a processor and Dealside is processing Personal Data on behalf of Customer as a sub-processor.

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5.2.4. For each module, where applicable the following applies:

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• The optional docking clause in Clause 7 does not apply.
• In Clause 9, Option 2 (general written authorization) applies, and the minimum time period for prior notice of sub-processor changes shall be as set forth in Section 3.2 of this DPA;
• In Clause 11, the optional language does not apply; 
• All square brackets in Clause 13 are hereby removed; 
• In Clause 17 (Option 1), the EU SCCs will be governed by the laws of Belgium (unless Data Protection Laws require it to be the country of Customer’s establishment);
• In Clause 18(b), disputes will be resolved before the courts of Belgium; 
• Exhibit B to this DPA contains the information required in Annex I of the EU SCCs; 
• Exhibit C to this DPA contains the information required in Annex II of the EU SCCs; and
• By entering into this DPA, the Parties are deemed to have signed the EU SCCs incorporated herein, including their Annexes.

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5.4. Ex-UK Transfers. The Parties agree that ex-UK Transfers shall be made pursuant to the UK International Data Transfer Addendum to the EU SCCs issued by the UK Information Commissioner (“UK Addendum”), which is hereby incorporated into this DPA by reference. The UK Addendum shall be deemed completed on the following basis:

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5.4.1. Table 1: Parties. The Parties and their key contact information are set out in Exhibit B of this DPA.

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5.4.2. Table 2: Selected SCCs, Modules and Selected Clauses. The Approved EU SCCs are the EU Standard Contractual Clauses referenced in Section 5.2 of this DPA, including the applicable Modules selected therein.

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5.4.3. Table 3: Appendix Information. The Appendix Information required by the UK Addendum is set out as follows::

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• Annex I.A (List of Parties): As per Table 1 above;
• Annex I.B (Description of Transfer): See Exhibit B of this DPA.
• Annex II (Technical and Organisational Measures): See Exhibit C of this DPA.
• Annex III (List of Sub processors) (Modules 2 and 3 only): The list of Authorized Sub-Processors is located at https://trust.askdonna.com/subprocessors

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5.4.4. Table 4: Both the Importer and the Exporter may end the UK International Data Transfer Addendum in accordance with the terms of the UK International Data Transfer Addendum.

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

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• References to the “General Data Protection Regulation” or “Regulation (EU) 2016/679” shall be interpreted to include the Swiss Federal Act on Data Protection (“FADP”).
• References to “supervisory authority” shall be interpreted to include the FDPIC with respect to data transfers subject to the FADP.
• References to “EU Member State” shall be interpreted in a manner that permits Data Subjects in Switzerland to exercise their rights in accordance with Clause 18(c) of the EU SCCs.
• Until the Revised FADP becomes fully effective, the SCCs shall be interpreted to protect Personal Data of legal entities as required under the FADP.

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

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5.6.1. As of the date of this DPA, 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) Customer’s Personal Data (“Government Agency Requests”).

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

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Section 6. Rights of Data Subjects and Assistance

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6.1. Data Subject Requests. Dealside shall, to the extent permitted by law, notify Customer upon receipt of a request by a Data Subject to exercise rights available to them under Data Protection Laws (such requests individually and collectively “Data Subject Request(s)”). If Dealside receives a Data Subject Request in relation to Customer’s Personal Data, Dealside will advise the Data Subject to submit their request to Customer and Customer will be responsible for responding to such request, including, where necessary, by using the functionality of the Services. To the extent Customer is unable to fulfil a Data Subject Request through the Services, and taking into account the nature of the Processing and the information available to Dealside, Dealside shall, upon Customer’s request, provide reasonable and timely assistance to enable Customer to comply with its obligations under applicable Data Protection Laws, to the extent permitted by such laws.

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6.2. Assistance. Taking into account the nature of the Processing and the information available to Dealside, Dealside shall provide Customer with reasonable cooperation and assistance, where necessary and where Customer does not otherwise have access to the relevant information, in order for Customer to comply with its obligations under applicable Data Protection Laws, including (a) responding to Data Subject Requests, (b) conducting data protection impact assessments, privacy impact assessments, or similar assessments required under Data Protection Laws; and (c) cooperating with, responding to, or consulting with any Regulatory Authority, to the extent required under Data Protection Laws. Such assistance shall be provided only where Customer is unable to comply independently and only to the extent permitted by applicable law.

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Section 7. Audit

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7.1. Compliance. The parties acknowledge that Customer must be able to assess Dealside’s compliance with its obligations under Applicable Data Protection Law and this DPA, insofar as Dealside is acting as a Processor on behalf of Customer.

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7.2. Dealside's Audit Program. Dealside uses external auditors to verify the adequacy of its security measures with respect to its processing of Customer’s Personal Data. Such audits are performed at least once annually at Dealside’s expense by independent third-party security professionals at Dealside’s selection and result in the generation of a confidential audit report ("Audit Report").

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7.3. Right of Audit by Customer. Upon Customer's reasonable written request, and subject to reasonable confidentiality controls, Dealside will make available to Customer a copy of Dealside’s most recent Audit Report. To the extent that Dealside’s provision of an Audit Report does not provide sufficient information or Customer is required to respond to a regulatory authority audit, Customer agrees to a mutually agreed-upon audit plan with Dealside that: (a) ensures the use of an independent third party; (b) provides written notice to Dealside in a timely fashion; (c) requests access only during business hours and requires that the audit be conducted in a manner that causes minimal disruption; (d) occurs no more than once (1) per two (2) years (unless a Personal Data Breach or suspected material non-compliance has occurred); (e) restricts its findings to only data relevant to Customer; and (f) obligates Customer, to the extent permitted by law or regulation, to keep confidential any information gathered that, by its nature, should be confidential.

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7.4. Corrective Action Plan. If an audit conducted pursuant to Section 7.3 reveals any material breach by Dealside of this Data Processing Agreement or applicable Data Protection Laws, Dealside shall, within twenty (20) working days of receiving the audit report, prepare and provide to Customer a written corrective action plan outlining the measures Dealside will take to remedy the identified non-compliance. Dealside shall implement the corrective actions in accordance with the agreed timelines set out in the corrective action plan.

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7.5. Audit Expenses. All audits conducted under Section 7.3 shall be at Customer’s expense, except where the audit reveals a material noncompliance by Dealside of this Data Processing Agreement or applicable Data Protection Laws, in which case Dealside shall bear the costs of the audit.

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Section 8. Dealside’s Role as a Controller

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8.1. Dealside’s Role as a Controller. The parties acknowledge and agree that with respect to Customer Account Data, Dealside is an independent controller, not a joint controller with Customer. Dealside will process Customer Account Data as a controller (i) to manage the relationship with Customer; (ii) to carry out Dealside’s core business operations, such as accounting, audits, tax preparation and filing and compliance purposes; (ii) to comply with legal or regulatory obligations applicable to the processing and retention of Personal Data to which Dealside is subject; and (iv) as otherwise permitted under Data Protection Laws and in accordance with this DPA and the Agreement.

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Section 9. Conflict

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9.1. 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 DPA; (3) the Agreement; and (4) any other written agreement executed by the parties. Any claims brought in connection with this DPA will be subject to the terms and conditions, including, but not limited to, the exclusions and limitations set forth in the Agreement.

Exhibit A

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Details of Processing

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Subject Matter of Processing: The processing activities may include, based on the features of the Services utilized, but are not limited to, providing pre-meeting briefings, recording meetings, generating meeting summaries, automating follow-ups, logging meeting notes, and updating CRM systems automatically through the Services.

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Purpose of the Processing: Dealside will process Customer’s Personal Data as necessary to provide the Services under the Agreement, for the purposes specified in the Agreement and this DPA, and in accordance with Customer’s instructions as set forth in this DPA. Dealside does not sell Customer’s Personal Data and does not share such data with third parties for compensation or for those third parties' own business interests. Dealside will not, and will not permit any third party to, use any Customer’s Personal Data to train or improve any AI models.

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Nature of Processing: Collection, organization, structuring, storage, consultation, use, disclosure by transmission, alignment or combination, restriction, modification and amendment, erasure or destruction.

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Duration of Processing: Prior to termination of the Agreement, Dealside will process Customer’s Personal Data until Customer elects to delete such Customer’s Personal Data through the Services. Following termination of the Agreement, Dealside shall have no right to process Personal Data, except (a) for processing required or authorized by applicable law or (b) as required to facilitate the return or deletion of Personal Data. Customer has the right to request the return or deletion of Personal Data within sixty (60) days after the termination effective date. Personal Data will be deleted from Dealside systems within ninety (90) days after the termination effective date.

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Categories of Data Subjects: Categories of Data Subjects may include, based on the features of the Services utilized, but is not limited to

• Customer’s Authorized Users
• Employees, agents, contractors, advisors, or other representatives of Customer (who are natural persons)
• Contact persons of the Customer’s prospects, customers, suppliers, and business partners
• Prospects, customers and business partners of Customer (who are natural persons)

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Categories of Personal Data: Categories of Personal Data may include, based on the features of the Services utilized, but is not limited to

• Identification data (first name, last name, email, mobile device ID, IP address, nationality, job title)
• Contact data (email, postal address, phone number)
• Meeting data (participant names, participant contact details, meeting metadata, audio and video recordings, transcripts, summaries, debriefs)
• Prospects, customers and business partners interaction data (notes, call summaries, interaction history)
• Chat and voice interactions of Authorized Users exchanged with or through the Services

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Sensitive Data or Special Categories of Data: Customers are prohibited from providing sensitive personal data or special categories of data to Dealside.

Exhibit B

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

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1. The Parties

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Data exporter(s):

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Name: Customer, as stated and defined in the applicable Order Form (as such term is defined under the Agreement)

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Address: Customer’s registered business address and any address provided to Dealside at the time that Customer uses the Services.

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Contact person’s name, position and contact details: Customer’s contact for the purposes of the SCC’s will be the contact of the person that properly accepts and binds Customer to the Agreement unless another contact person’s information is specifically provided to Dealside in writing.

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Activities relevant to the data transferred under these Clauses: As set forth in Section 2 of the DPA.

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Signature and date: By entering into the Agreement, Data Importer is deemed to have signed these EU SCC and UK Addendum, incorporated herein, including their Annexes, as of the effective date of the Agreement.

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Role (controller/processor): The Data Exporter’s role is set forth in Section 2 of this DPA.

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Data importer(s):

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Name: Dealside BV

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Address: Frans Ackermanstraat 20, 9000 Ghent, Belgium

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Contact person’s name, position and contact details: Dealside Privacy Team, privacy@dealside.com

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Activities relevant to the data transferred under these Clauses: As set forth in Section 2 of the DPA.

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Signature and date: By entering into the Agreement, Data Importer is deemed to have signed these EU SCC and UK Addendum, incorporated herein, including their Annexes, as of the effective date of the Agreement.

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Role (controller/processor): The Data Importer’s role is set forth in Section 2 of this DPA.

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2. Description of the Transfer

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Data Subjects: As described in Exhibit A of the DPA

Categories of Personal Data: As described in Exhibit A of the DPA

Special Category Personal Data (if applicable): As described in Exhibit A of the DPA

Nature of the Processing: As described in Exhibit A of the DPA

Purposes of Processing: As described in Exhibit A of the DPA

Duration of Processing and Retention (or the criteria to determine such period): As described in Exhibit A of the DPA

Frequency of the transfer: As necessary to perform all obligations and rights with respect to Personal Data as provided in the Agreement or DPA

Recipients of Personal Data Transferred to the Date Importer: Dealside will maintain a list of Authorized Sub-Processors at https://trust.askdonna.com/subprocessors

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3. Competent Supervisory Authority

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The supervisory authority shall be the supervisory authority of the Data Exporter, as determined in accordance with Clause 13 of the EU SCCs. The supervisory authority for the purposes of the UK Addendum shall be the UK Information Commissioner’s Officer.

Exhibit C

‍Description of the Technical and Organisational Security Measures implemented by the Data Importer.

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The following includes the information required by Annex II of the EU SCCs and Annex II of the UK Addendum.

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1. Access control

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Measures to prevent access to data processing systems for unauthorized persons and to prevent unauthorized activities, which are not included in the given user authorizations.

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(a) Authentication: Dealside uses secure access protocols. Access to production infrastructure requires the use of multi-factor authentication.

(b) Authorization: Dealside restricts access to Customer’s Personal Data to authorized personnel with a defined need-to-know or a role requiring such access, using role-based access control (RBAC).

(c) Review: Access rights to Customer’s Personal Data are regularly reviewed.

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2. Encryption of personal data and pseudonymization

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Measures for the protection of data during storage and during transmission.

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(a) Encryption at rest: Customer’s Personal Data stored in databases and file systems is encrypted at rest using secure encryption algorithms.

(b) Encryption in transit: Customer’s Personal Data is encrypted in transit using secure cipher suites and protocols for transmission over public networks.

(c) Pseudonymization: Customer’s Personal Data is pseudonymized or anonymized where relevant and feasible.

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3. Physical security

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Measures for ensuring physical security of locations at which personal data are processed.

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(a) Customer’s Personal Data is hosted in ISO27001-certified and SOC2-compliant data centers at leading cloud infrastructure providers. Facilities have 24/7 security monitoring, access controls, and CCTV surveillance.

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4. Backup and disaster recovery

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Measures for ensuring the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident.

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(a) Backup: Production database backups are created automatically on a daily basis and are redundantly stored for 7 days.

(b) Disaster recovery: A disaster recovery plan outlines the steps to take to perform backup recovery and is tested regularly.

(c) Redundancy: Redundant infrastructure prevents single points of failure. Systems use automated failover and load balancing.

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5. Logging and monitoring

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Measures for ensuring event logging and monitoring.

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(a) Logging: Dealside logs events and captures and stores logs that include all interactions and relevant modifications.

(b) Monitoring: Logs and events are monitored and investigated when necessary and escalated appropriately.

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6. Retention and secure deletion

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Measures for ensuring data retention and secure deletion.

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(a) Retention: Customer’s Personal Data is stored only as long as necessary.

(b) Secure deletion: Secure deletion of Customer’s Personal Data is performed using industry-standard methods when retention periods expire or upon request.

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7. Sub-processors

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Technical and organizational measures of sub-processors

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(a) Agreements: Dealside enters into data processing agreements with its Authorized Sub-Processors with data protection obligations substantially similar to those contained in this DPA.

(b) Review: Authorized Sub-Processors are regularly reviewed to ensure ongoing compliance with security measures and GDPR requirements.

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8. Certification

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Technical and organizational measures for certification

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(a) Certification: Dealside undergoes annual independent ISO27001 and SOC 2 audits.

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