Data Processing Addendum

This Data Processing Addendum ("DPA") forms part of the Master Services Agreement or Terms of Service available at https://transcrypt.com/terms.

1. Definitions

"Controller" means the entity that determines the purposes and means of the processing of Personal Data.

"Processor" means the entity that processes Personal Data on behalf of the Controller.

2. Data Processing

Transcrypt shall process Personal Data only on behalf of the Customer and in accordance with Customer's documented instructions, including with regard to transfers of Personal Data to a third country or an international organization, unless required to do so by Union or Member State law to which the Processor is subject.

3. Security Measures

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

• The pseudonymization and encryption of personal data;
• The ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;