Data Processing Addendum

This Data Processing Addendum, including its Schedules and Appendices, (“DPA”) forms part of the Terms of Services, either written or electronic, between ChMeetings and Client for the purchase of services from ChMeetings (identified either as “Services” or otherwise in the Terms of Services, and hereinafter defined as “Services”) to reflect the parties’ agreement with regard to the Processing of Personal Data.

Client enters this DPA on behalf of itself and, to the extent required under applicable Data Protection Laws and Regulations. For the purposes of this DPA only, and except where indicated otherwise, the term “Client” shall include Client, and the term “Supplier” shall refer to ChMeetings and Authorized Affiliates. All capitalized terms not defined herein shall have the meaning set forth in the Terms of Services.

While providing the Services to Client pursuant to the Terms of Services, Supplier may Process Personal Data on behalf of Client and the Parties agree to comply with the following provisions with respect to any Personal Data, each acting reasonably and in good faith.

Definitions

Affiliate” means any entity that directly or indirectly controls, is controlled by, or is under common control with the subject entity. “Control,” for purposes of this definition, means direct or indirect ownership or control of more than 50% of the voting interests of the subject entity.

Authorized Affiliate” means any of Supplier’s Affiliate(s) which (a) is subject to the data protection laws and regulations of the European Union, the European Economic Area and/or their member states, Switzerland and/or the United Kingdom, and (b) is permitted to provide the Services pursuant to the Terms of Services between Client and Supplier, but it isn’t part of the Terms of Services and is not a “Supplier” as defined under this DPA.

Controller” means the entity which determines the purposes and means of the Processing of Personal Data.

Client” means the entity that executed the DPA together with its Affiliates (for so long as they remain Affiliates) which have agreed with Terms of Services when creating an user account.

Client Data” means what is defined in this DPA as “Client Data” or “Your Data”, provided that such data is electronic data and information submitted by or for Client to the Services.

Data Protection Laws and Regulations” means all laws and regulations, including laws and regulations of the European Union, the European Economic Area and their member states, Switzerland, the United Kingdom, applicable to the Processing of Personal Data under the Terms of Services.

Data Subject” means the identified or identifiable person to whom Personal Data relates.

GDPR” means 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).

Personal Data” means any information relating to an identified or identifiable natural person.

Processing” means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Processor” means the entity which Processes Personal Data on behalf of the Controller.

Standard Contractual Clauses” means the agreement executed by and between Client and Supplier and attached hereto as Schedule 2 pursuant to art. 46 of GDPR and to the European Commission’s decision (C(2010)593)/ (2010/87/EU) of 5 February 2010 on Standard Contractual Clauses for the transfer of personal data to processors established in third countries which do not ensure an adequate level of data protection.

Sub-processor” means any Processor engaged by Supplier.

Supervisory Authority” means an independent public authority which is established by an EU Member State pursuant to the GDPR.

Supplier” means ChMeetings and its Affiliates engaged in the Processing of Personal Data.

Processing of personal data

Roles of the Parties. The parties acknowledge and agree that regarding the Processing of Personal Data, Client is the Controller, Supplier is the Processor.

Client’s Processing of Personal Data. Client shall, in its use of the Services, Process Personal Data in accordance with the requirements of Data Protection Laws and Regulations, including any applicable requirement to provide notice to Data Subjects of the use of Supplier as Processor. For the avoidance of doubt, Client’s instructions for the Processing of Personal Data shall comply with Data Protection Laws and Regulations. Client shall have sole responsibility for the accuracy, quality and legality of Personal Data and how Client acquired Personal Data.

Supplier Processing of Personal Data. Supplier shall treat Personal Data as Confidential Information and shall Process Personal Data on behalf of and only in accordance with Client’s documented instructions for the following purposes: (i) Processing in accordance with Terms of Services; and (ii) Processing to comply with other documented reasonable instructions provided by Client (e.g., via email) where such instructions are consistent with the terms of Terms of Services.

Details of the Processing. The Processing of Personal Data by Supplier is the performance of the Services pursuant to Terms of Services. The duration of the Processing, the nature and purpose of the Processing, the types of Personal Data and categories of Data Subjects processed under this DPA are further specified in Schedule 1 (Details of the Processing) to this DPA.

Supplier Personnel

Confidentiality. Supplier shall ensure that its personnel engaged in the Processing of Personal Data are informed of the confidential nature of the Personal Data, have received appropriate training on their responsibilities and have executed written confidentiality agreements. Supplier will assume full responsibility for any disclosure of the Personal Data made by Supplier’s Personnel. Supplier shall ensure that such confidentiality obligations prevail and could terminate the personnel engagement.

Reliability. Supplier shall take commercially reasonable steps to ensure the reliability of any Supplier personnel engaged in the Processing of Personal Data.

Limitation of Access. Supplier shall ensure that Supplier’s access to Personal Data is limited to those personnel performing Services in accordance with Terms of Services.

Sub-Processors

Appointment of Sub-processors. Client acknowledges and agrees that (a) Supplier’s Affiliates may be retained as Sub-processors and (b) Supplier and Supplier’s Affiliates respectively may engage third-party Sub-processors in connection with the provision of the Services. Supplier or an Supplier Affiliate has to enter into a written agreement with each Sub-processor containing data protection obligations not less protective than those in this DPA with respect to the protection of Client Data to the extent applicable to the nature of the Services provided by such Sub-processor.

List of Current Sub-processors and Notification of New Sub-processors. Supplier shall make available to Client the current list of Sub-processors for the Services identified in Appendix 3 of the Standard Contractual Clauses attached hereto. Such Sub-processor lists shall include the identities of those Sub-processors and their country of location. Supplier shall provide notification of a new Sub-processor(s) before authorizing any new Sub-processor(s) to Process Personal Data in connection with the provision of the provided Services.

Objection Right for New Sub-processors. Client may object to Supplier’s use of a new Sub-processor by notifying Supplier promptly in writing within thirty (30) days after receipt of Supplier’s notice in accordance with the mechanism set out in “List of Current Sub-processors and Notification of New Sub-processors”. In the event Client objects to a new Sub-processor, as permitted in the preceding sentence, Supplier will use reasonable efforts to make available to Client a change in the Services or recommend a commercially reasonable change to Client’s configuration or use of the Services to avoid Processing of Personal Data by the objected-to new Sub-processor without unreasonably burdening Client. If Supplier is unable to make available such change within a reasonable period, which shall not exceed thirty (30) days, (i) Supplier shall stop using that new Sub-processor in connection with the provision of the provided Services; or (ii) Client may terminate the Services and Supplier will refund Client any prepaid fees covering the remainder of the term of such Services, without imposing a penalty for such termination on Client.

Liability. Supplier shall be liable for the acts and omissions of its Sub-processors to the same extent Supplier would be liable if performing the services of each Sub-processor directly under the terms of this DPA, except as otherwise set forth in Terms of Services.

Rights of data subjects

Data Subject Request. Supplier shall, to the extent legally permitted, promptly notify Client if Supplier receives a request from a Data Subject to exercise the Data Subject’s right of access, right to rectification, restriction of Processing, erasure (“right to be forgotten”), data portability, object to the Processing, or its right not to be subject to an automated individual decision making, each such request being a “Data Subject Request”. Considering the nature of the Processing, Supplier shall assist Client by appropriate technical and organizational measures, insofar as this is possible, for the fulfilment of Client’s obligation to respond to a Data Subject Request under Data Protection Laws and Regulations.

Security

Controls for the Protection of Client Data. Supplier shall maintain appropriate technical and organizational measures for protection of the security (including protection against unauthorized or unlawful Processing and against accidental or unlawful destruction, loss or alteration or damage, unauthorized disclosure of, or access to, Client Data), confidentiality and integrity of Client Data. Supplier regularly monitors compliance with these measures.

Security of processing. 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, the Processor shall implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including inter alia as appropriate:

  1. the pseudonymization and encryption of Personal Data;
  2. the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and Services;
  3. the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident;
  4. a process for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures for ensuring the security of the Processing.

GDPR Assessments. Upon Client’s written request at reasonable intervals, and subject to the confidentiality obligations set forth in Terms of Services, Supplier shall make available to Client that is not a competitor of Supplier (or Client’s independent, third-party auditor that is not a competitor of Supplier) a copy of Supplier’s most recent third-party audits.

Data Protection Impact Assessment. Upon Client’s request, Supplier shall provide Client with reasonable cooperation and assistance needed to fulfil Client’s obligation under the GDPR to carry out a data protection impact assessment related to Client’s use of the Services, to the extent Client does not otherwise have access to the relevant information, and to the extent such information is available to Supplier. Supplier shall provide reasonable assistance to Client in the cooperation or prior consultation with the Supervisory Authority in the performance of its tasks relating to this Section of this DPA, to the extent required under the GDPR.

Client data incident management and notification

Client Data Incident. Supplier shall maintain security incident management policies and shall notify Client without undue delay after becoming aware of the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Client Data, including Personal Data, transmitted, stored or otherwise Processed by Supplier or its Sub-processors of which Supplier becomes aware.

Return and deletion of client data

Deletion procedure. Supplier shall return Client Data to Client and, to the extent allowed by applicable law, delete Client Data in accordance with the procedures and timeframes specified in the Privacy Policy.

Transfer of personal data

Transfer mechanism for data transfers. Subject to the additional terms in Schedule 2, the transfer mechanisms shall apply to any transfers of Personal Data under this DPA from the European Union, the European Economic Area and/or their member states, Switzerland and the United Kingdom to countries which do not ensure an adequate level of data protection within the meaning of Data Protection Laws and Regulations of the foregoing territories, to the extent such transfers are subject to such Data Protection Laws and Regulations.

General provisions

GDPR. Supplier will Process Personal Data in accordance with the GDPR requirements directly applicable to Supplier’s provision of its Services.

Legal effect. This DPA shall become legally binding between Client and Supplier once the Client creates an User Account and accepts Supplier’s Terms of Services and Privacy Policy, and it will terminate at the termination date of the last Services provided under Terms of Services.

List of Schedules and Appendices

Schedule 1: Details of the Processing

Schedule 2: Standard Contractual Clauses

Appendix 1 (Schedule 2): Details of the Processing for transferred personal data

Appendix 2 (Schedule 2): Description of the technical and organizational security measures implemented by the data importer

Appendix 3 (Schedule 2): List of authorized subcontractors

 

Schedule 1 – Details of the processing

Nature and Purpose of Processing

Supplier will Process Personal Data as necessary to perform the Services pursuant to Terms of Services and as further instructed by Client in its use of the Services.

Duration of Processing

Subject to “Return and deletion of client data” Section of this DPA, Supplier will Process Personal Data for the duration of the User Account, unless otherwise agreed upon in writing.

Categories of Data Subjects

Client may share Personal Data in regard to receiving the Services, the extent of which is determined and controlled by Client in its sole discretion, and which may include, but is not limited to Personal Data relating to the following categories of Data Subjects:

  • Client’s groups and members
  • Client’s Users authorized by Client to use ChMeetings platform

Type of Personal Data

Client may share Personal Data about receiving the Services, the extent of which is determined and controlled by Client in its sole discretion, and which may include, but is not limited to the following categories of Personal Data:

  • First and last name
  • Contact information (email, phone)
  • Address
  • Personal life data
  • Localization data

Processing activities

The objective of Processing of Personal Data by Supplier is the performance of the Services pursuant to Terms of Services.

 

Schedule 2 – Standard Contractual Clauses

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, and in accordance with Article 46 (2) of GDPR.

Client is the data exporter and Supplier is 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.

Clause 1

Definitions. For the purposes of the Clauses:

  1. ‘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;
  2. ‘the data exporter’ means the controller who transfers the personal data;
  3. ‘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;
  4. ‘the sub-processor’ means any processor engaged by the data importer or by any other sub-processor of the data importer who agrees to receive from the data importer or from any other sub- processor 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;
  5. ‘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;
  6. ‘technical and organizational security measures’ means those measures aimed at protecting personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorized 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 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 sub-processor 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 sub-processor 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:

  1. 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;
  2. 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;
  3. that the data importer will provide sufficient guarantees in respect of the technical and organizational security measures specified in Appendix 2 to this contract;
  4. 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, unauthorized 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;
  5. that it will ensure compliance with the security measures;
  6. 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;
  7. 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;
  8. 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 Clauses or the contract contain commercial information, in which case it may remove such commercial information;
  9. 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
  10. that it will ensure compliance with Clause 4(a) to (i).

Clause 5

Obligations of the data importer. The data importer agrees and warrants:

  1. 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;
  2. 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;
  3. that it has implemented the technical and organizational security measures specified in Appendix 2 before processing the personal data transferred;
  4. that it will promptly notify the data exporter about:
  5. 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,
  6. any accidental or unauthorized access, and
  7. any request received directly from the data subjects without responding to that request, unless it has been otherwise authorized to do so;
  8. 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;
  9. 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;
  10. 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;
  11. that, in the event of subprocessing, it has previously informed the data exporter and obtained its prior written consent;
  12. that the processing services by the subprocessor will be carried out in accordance with Clause 11;
  13. 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.

 

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:
    1. to refer the dispute to mediation, by an independent person or, where applicable, by the supervisory authority;
    2. 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

Sub-processing

  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. 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.

 

Appendix 1 to the Standard Contractual Clauses

The Member States may complete or specify, according to their national procedures, any additional necessary information to be contained in this Appendix.

Data exporter

The data exporter is (please specify briefly your activities relevant to the transfer):

Data Exporter is the Client which is subject to the data protection laws and regulations of the European Union, the European Economic Area and/or their member states, Switzerland and/or the United Kingdom and its Authorized Affiliates.

Data importer

The data importer is (please specify briefly activities relevant to the transfer):

ChMeetings.com is a provider of a professional application to organize churches and ministries, which processes personal data upon the instruction of the data exporter in accordance with the terms of Terms of Services.

Data subjects

The personal data transferred concern the following categories of data subjects (please specify):

Data exporter may share Personal Data to receive the SCC Services, the extent of which is determined and controlled by the data exporter in its sole discretion, and which may include, but is not limited to Personal Data relating to the following categories of data subjects:

  • Client’s groups and members
  • Client’s Users authorized by Client to use ChMeetings platform

Categories of data

The personal data transferred concern the following categories of data (please specify):

Data exporter may share Personal Data to receive the SCC Services, the extent of which is determined and controlled by the data exporter in its sole discretion, and which may include, but is not limited to the following categories of Personal Data:

  • First and last name
  • Contact information (email, phone)
  • Address
  • Personal life data
  • Localization data

Processing activities

The personal data transferred will be subject to the following basic processing activities (please specify):

The objective of Processing of Personal Data by data importer is the performance of the SCC Services pursuant to Terms of Services.

 

Appendix 2 to the Standard Contractual Clauses

Description of the technical and organizational security measures implemented by the data importer in accordance with Clauses 4(d) and 5(c) (or document/legislation attached):

Data importer will maintain administrative, physical, and technical safeguards for protection of the security, confidentiality and integrity of Personal Data shared for providing the SCC Services.

 

Appendix 3 to the Standard Contractual Clauses

List of authorized subcontractors:

  • Microsoft Corporation
  • Twilio Inc.
  • Stripe Inc.
  • The Rocket Science Group LLC.
  • Google LLC
  • Hotjar Ltd.
  • NewRelic Inc.

Last modified on November 9, 2020.