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Data Processing Agreement

Data Processing

To execute this agreement, please download the PDF version and send the signed copy to legal@pelcro.com for a countersigned version.

Last updated September 28, 2026

The terms of this Data Processing Agreement ("DPA") govern your use of the "Services" of Pelcro Inc. ("Pelcro"), a corporation incorporated in Canada with offices at 3555 Côte-des-Neiges, #1810, Montreal, Quebec, Canada, as defined in:

  • the online Terms and Conditions you have entered into with Pelcro, or

  • in any offline agreement you may have entered into with Pelcro.

By accepting the terms below or by using Pelcro's Services in any manner, you and the entity you represent ("Customer") agree that you have read and agree to be bound by the DPA. Pelcro and Customer may collectively be referred to as the "Parties" in the DPA.

If you have any questions or concerns with the terms of the DPA, and/or any of the aforementioned agreements, please reach out to us at legal@pelcro.com.

  • WHEREAS the Customer wishes to contract certain Services, which include the processing of personal data, to Pelcro, the "Data Processor" or "Service Provider". Any reference to Data Processor or Service Provider in the DPA shall mean Pelcro. The Parties agree that in respect of any personal Data processed in connection with the DPA that Customer shall be the "Data Controller" or "Business" or "Organization" as defined by any applicable privacy regulations.

  • WHEREAS the Parties seek to implement a DPA that complies with the requirements of current legal privacy regulations as applicable, in relation to processing of personal data or personal information, including 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 (General Data Protection Regulation), the UK GDPR and the Swiss Federal Act on Data Protection.

  • WHEREAS the Parties wish to specify their respective rights and obligations.

It is agreed as follows:

1. Definitions and Interpretation

Unless otherwise defined herein, the terms and expressions used in the DPA shall have the following meaning:

"Canadian Privacy Laws" means the Personal Information Protection and Electronic Documents Act and substantially similar provincial legislation, as well as any applicable federal or provincial privacy or data protection legislation applicable to institutions and organizations in Canada, each together with the regulations thereto and as amended from time-to-time.

"CCPA" means the California Consumer Privacy Act, Cal. Civ. Code § 1798.100 et seq., and its implementing regulations.

"Data Localization Laws" means all laws and regulations which impose data localization obligations, to the extent applicable to the Processing of Personal Data under the DPA, as amended from time to time.

"Data Protection Laws" means all laws and regulations, including laws and regulations of the European Union, the European Economic Area and their member states (including, without limitation, the GDPR), Switzerland, the United Kingdom, Canada (including, without limitation, the Canadian Privacy Laws) and the United States of America and its states, to the extent applicable to the Processing of Personal Data under the DPA as amended from time to time.

"Data Transfer" means: a transfer of Personal Data from Customer to the Data Processor; or an onward transfer of Personal Data from Data Processor to a Sub-processor;

"DPA" means this Data Processing Agreement and all Schedules and Annexes.

"EU Personal Data" means any personal data that is subject to the laws and regulations of the European Union, the European Economic Area and their member states (including, without limitation, the GDPR), Switzerland, the United Kingdom.

"GDPR" means EU General Data Protection Regulation 2016/679;

"Standard Contractual Clauses" or "SCCs" means the standard contractual clauses for the transfer of personal data to third countries set out in the Annex to Commission Implementing Decision (EU) 2021/914 of 4 June 2021.

"Swiss FADP" means the Swiss Federal Act on Data Protection of 25 September 2020, as amended from time to time.

"UK Addendum" means the International Data Transfer Addendum to the EU Commission Standard Contractual Clauses (version B1.0) issued by the UK Information Commissioner under section 119A of the UK Data Protection Act 2018, as amended from time to time.

"UK GDPR" means the GDPR as it forms part of the law of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018.

"Personal Data" means any information contained or included in Customer Data relating to

  • an identified or identifiable natural person and,

  • an identified or identifiable legal entity where such information is protected similarly as personal data, personal information or personally identifiable information under applicable Data Protection Laws.

"Sub-Processor" means any person appointed by or on behalf of Data Processor to process Personal Data on behalf of Customer in connection with the DPA, and as further specified in Section 2.4.

The terms, "Commission", "Controller", "Data Subject", "Member State", "Personal Data", "Personal Data Breach", "Processing" and "Supervisory Authority" shall have the same meaning as in the GDPR, and their related terms shall be construed accordingly.

2. Data Processing Terms (All Jurisdictions)

When the Customer transfers Personal Data to Data Processor for Data processor to Process in the course of providing any Services, or Data Processor collects Personal Data on behalf of Customer for the purpose of providing Services to Customer, the parties intend and are of the view that the Customer will be the Controller and Data processor will be a Processor in relation to such Personal Data and that Data Processor or its Affiliates will engage Sub-processors in accordance with the DPA.

The parties agree that any Personal Data that the Customer transfers to Data Processor shall remain within the custody and control of the Customer, and as between the Customer and Data Processor, the Customer shall be the owner of such data.

Notwithstanding the above, Customer acknowledges and agrees that if Customer shares or authorizes any third party or related party to receive or view Customer Data directly in the application or via the use of any application integrations, the further processing by such third party or related party is not covered by the DPA.

2.1. Data Processor Obligations:

  • comply with all applicable Data Protection Laws in the Processing of Personal Data;

  • only process Personal Data on behalf of and in accordance with the Customer’s lawful written instructions from time-to-time (including as set out in the DPA) or as required for Data Processor to provide, manage and facilitate the provision of the Services, but only where such instructions are consistent with the terms of the DPA and only in respect of the subject matter, duration, nature and purpose of the Services, and the type of Personal Data and categories of Data Subject relevant to the Services;

  • not Process Personal Data other than on the Customer's documented instructions, except if required pursuant to applicable legislation to which Data Processor is subject, in which case Data Processor shall inform Customer of such requirement before Processing unless prohibited by law;

  • ensure that only authorized persons process such Personal Data and that such persons are subject to appropriate obligations to maintain the confidentiality of such Personal Data, and

  • upon the Customer’s request, and at Customer’s cost, Data Processor shall provide the Customer with reasonable cooperation and assistance needed to fulfil the Customer’s obligation (if any) under the Data Protection Laws to carry out a data protection impact assessment or any other similar assessment related to the Customer’s use of the Services, to the extent the Customer does not otherwise have access to the relevant information, and to the extent such information is available to Data Processor.

2.2. Customer Obligations:

  • Where the Customer transfers or otherwise makes available Personal Data to Data Processor in relation to the Services, the Customer warrants and represents that it has the necessary rights to transfer or make available such Personal Data to Data Processor (including that it has, or has procured, the necessary legal authority, permissions and/or consents for Data Processor to Process the Personal Data to provide the Services); the Customer’s instructions to Data Processor comply with (and will not cause Data Processor to be in breach of) the Data Protection Laws or any Data Localization Laws; and the Customer has taken reasonable steps to ensure that any Data Subjects are aware of the nature of the Processing to be undertaken, including by providing any notices required by applicable law or Regulatory Authority, or has otherwise complied with applicable Data Protection and Localization Laws in relation to informing Data Subjects concerning the Processing of their Personal Data comprised in the Customer Data. The Customer shall have sole responsibility for the accuracy, quality, and legality of Personal Data and the means by which the Customer acquired Personal Data. The Customer specifically acknowledges that its use of the Services will not violate the rights of any Data Subject, including the rights of any Data Subject that has opted-out from sales or other disclosures of Personal Data to the extent applicable under the CCPA or other similar regulatory requirements.

  • The subject-matter of Processing of Personal Data by the Data Processor is the performance of the Services pursuant to the DPA. The duration of the Processing, the nature and purpose of the Processing, the types of Personal Data and categories of Data Subjects Processed under the DPA are further specified in Schedule 1 to the DPA.

2.3. Security

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, Data Processor shall in relation to Personal Data implement appropriate technical and organizational measures to ensure a level of security appropriate to that risk, including, as appropriate, the measures referred to in Article 32(1) of the GDPR.

  • Hosting Location. Pelcro hosts Customer Data on Amazon Web Services in the US East (Ohio) region (us-east-2) in the United States. AI features of the Services process Personal Data through Amazon Bedrock, with inference restricted to AWS regions in the United States.

2.4. Sub-Processors

  • Appointment of Sub-Processors. Customer acknowledges and agrees that: (a) Data Processor affiliates may be retained as Sub-Processors; and (b) Data Processor and Data Processor affiliates may engage third-party Sub Processors in connection with the provision of the Services. Data Processor or a Data Processor affiliate will enter into a written agreement with the Sub-Processor containing data protection obligations not less protective than those in the DPA, with respect to the Customer Data to the extent applicable to the nature of the Services provided by such Sub-processor. In case the Sub-Processor fails to fulfill its data protection obligations under such a written agreement with Data Processor, Data Processor will remain liable to the Customer for the performance of the Sub Processor's obligations under such agreement.

  • List of Current Sub-Processors. the Data Processor shall make available a list of Sub-Processors for the Services. A current list of the Pelcro Sub-Processors can be found at https://www.get.pelcro.com/subprocessors. Pelcro will update the list to reflect any addition, replacement or other changes to Pelcro's Sub-Processors.

  • Authorization. Customer's acceptance of the DPA shall be considered written authorization for Pelcro to engage the Sub-Processors as reflected on the list of Sub-Processors current as of the date of signing the DPA. Pelcro will notify Customer of any new Sub-processor at least 30 days before authorizing it to Process Personal Data in connection with the provision of the applicable Services. Customer may subscribe to these notifications by emailing legal@pelcro.com. If Customer objects to the appointment of any such Sub-processor within that 30-day notice period on reasonable grounds related to the protection of Personal Data, Data Processor will work in good faith with Customer to find an alternative solution. In the event that parties are unable to find such a solution, Customer may terminate the DPA at no additional cost.

2.5. Data Subject Rights

  • Data Subject Request. Taking into account the nature of the Processing, Data Processor shall assist Customer by implementing appropriate technical and organizational measures, insofar as this is possible, for the fulfilment of Customer obligations, to respond to requests to exercise Data Subject rights under the Data Protection Laws.

  • Obligations. Data Processor shall: promptly notify Customer if it receives a request from a Data Subject under any Data Protection Law in respect of Data Subject Personal Data; and ensure that it does not respond to a Data Subject request except on the documented instructions of Customer or as required by Data Protection Laws to which the Data Processor is subject, in which case Data Processor shall to the extent permitted by Data Protection Laws inform Customer of that legal requirement before Data Processor responds to the request.

2.6. Personal Data Breach

  • Notification. Data Processor shall notify Customer without undue delay, and in any event within 48 hours, after Data Processor becomes aware of a Personal Data Breach affecting Personal Data, providing Customer with sufficient information to allow Customer to meet any obligations to report or inform Data Subjects of the Personal Data Breach under the Data Protection Laws.

  • Remediation. Data Processor shall make reasonable efforts to identify the cause of such Customer Data Incident and take those steps as Data Processor deems necessary and reasonable in order to remediate the cause of such a Customer Data Incident to the extent the remediation is within Data Processor’s reasonable control.

2.7. Deletion or return of Personal Data

Upon written request from Customer made within 30 days after termination of the DPA, Data Processor shall return Customer Data to Customer as described in Section 6.4 of the Terms and Conditions. Data Processor shall delete Customer Data, including copies held in backups, within 30 days after the end of that 30-day period, unless applicable law requires Data Processor to retain it. Any Customer Data retained under applicable law will continue to be protected in accordance with the DPA and Processed only as required by that law.

2.8. Audit rights

  • Accountability. Subject to reasonable access arrangements being agreed between the parties and save for disclosure of information which is confidential and/or privileged (or where access is otherwise restricted by applicable law or regulation), Data Processor shall make available to the Customer all relevant information reasonably necessary to demonstrate compliance with Data Processor’s obligations under the GDPR and allow for and contribute to audits, including inspections, conducted by the Customer or another auditor mandated by the Customer, at the Customer’s cost.

  • Legality of Instructions. Data Processor shall immediately inform Customer if any Customer instructions related to the processing of the Personal Data as related to the provision of the Services infringes EU Data Protection Laws.

2.9. Legally Required Changes.

Regulatory Changes. Pelcro and Customer acknowledge that laws relating to privacy and data protection are evolving and that amendment to the DPA may be required to ensure compliance with such developments. The parties agree to take such action as is necessary to implement changes to the standards and requirements of any Data Protection and Localization Laws as applicable to one or both of the parties, including negotiating in good faith to amend the DPA as necessary or prudent for compliance with such laws.

3. Data Processing Terms (CCPA Specific Provisions)

Scope of Data Processing Terms. Sections 3.1 to 3.3 apply only with respect to California Personal Information.

3.1. Roles of the Parties. When processing California Personal Information in accordance with Customer Instructions, the parties acknowledge and agree that Customer is a Business and Pelcro is a Service Provider for the purposes of the CCPA.

3.2. Responsibilities. The parties agree that Pelcro will Process California Personal Information as a Service Provider strictly for the purpose of performing the Services under the DPA (the "Business Purpose") or as otherwise permitted by the CCPA. Pelcro will not sell any personal information; retain, use or disclose any personal information for any purpose other than for the specific purpose of providing the Services, including retaining, using, or disclosing the personal information for a commercial purpose other than the provision of the Service; or retain, use or disclose the personal information outside of the direct business relationship between the parties.

3.3. Certification. Pelcro certifies that it understands the restrictions in this section 3 and will comply with them.

4. Data Processing Terms (Canada Specific Provisions)

4.1. Scope of Data Processing Terms. Sections 4.1 to 4.8 shall apply only with respect to Processing of Personal Data about Canadian Data Subjects on behalf of Customers or Employers operating within Canada.

4.2. Compliance with Canadian Privacy Laws. Pelcro and Customer will each Process the Personal Data in accordance with all applicable Canadian Privacy Laws.

4.3. Protection of Personal Data. Pelcro will take reasonable steps to protect the Personal Data against such risks as unauthorized access, use, disclosure, destruction or alteration.

4.4. Consent Requirements. Customer shall provide any required notices and obtain any required consents, as needed, for Pelcro to access, use, store and otherwise Process Personal Data outside Canada. Pelcro will take reasonable steps to ensure that Personal Data transferred outside the province where such information is collected is not used for any unauthorized purpose, and that Personal Data accessed, used, stored or otherwise Processed outside Canada is protected by appropriate safeguards.

4.5. Customer Record Keeping. Customer shall keep appropriate records of all notices provided, and all consents obtained, pursuant to Section 4.4 above, and Customer shall promptly provide evidence of such notices and consents to Pelcro upon Pelcro’ request.

4.6. Data Minimization. Customer shall ensure that the Customer Data contains only the minimum Personal Data (if any) required by Pelcro to provide the Services.

4.7. Cooperation. The parties agree to reasonably cooperate and assist each other to comply with their respective obligations under applicable Canadian Privacy Laws, including, to the extent permitted by applicable laws, to respond to audits, requests, demands and investigations by any Regulatory Authority.

4.8. Roles and Responsibilities of the Parties. Pelcro will Process Personal Data as a service provider strictly for the purpose of performing the Services under the DPA (including as instructed by Customer) or permitted by the Canadian Privacy Laws or required by applicable laws.

5. International Data Transfers

5.1. Adequacy

Pelcro Inc. is established in Canada. The European Commission has recognized Canada as providing an adequate level of protection for personal data (Decision 2002/2/EC), and the United Kingdom and Switzerland recognize Canada as adequate under their own laws. Transfers of EU Personal Data from Customer to Pelcro rely on these adequacy decisions. The Standard Contractual Clauses in Sections 5.2 to 5.4 apply to any transfer of EU Personal Data to Pelcro to the extent an adequacy decision does not cover it, including if an adequacy decision is suspended, withdrawn or invalidated.

5.2. EU Standard Contractual Clauses

The Parties agree that, without any further action being required, they have entered into the Standard Contractual Clauses, which are incorporated into the DPA by reference, as follows:

  • Module Two (controller to processor) applies where Customer is a Controller, and Module Three (processor to processor) applies where Customer is a Processor acting on behalf of a third-party Controller;

  • Customer is the "data exporter" and Pelcro is the "data importer";

  • Clause 7 (docking clause) applies;

  • in Clause 9, Option 2 (general written authorization) applies, and the time period for prior notice of Sub-processor changes is 30 days, as set out in Section 2.4;

  • in Clause 11, the optional language does not apply;

  • in Clause 13, the competent supervisory authority is the supervisory authority of the EU Member State in which Customer is established or, where Customer is not established in the EU, the supervisory authority of the Member State in which Customer's representative is established or in which the Data Subjects are located, as determined under Clause 13(a);

  • in Clause 17, Option 1 applies, and the SCCs are governed by the law of the EU Member State in which Customer is established or, where that law does not allow for third-party beneficiary rights, by the law of Ireland;

  • in Clause 18(b), disputes are resolved before the courts of the EU Member State whose law governs under Clause 17;

  • Annex I (List of Parties, Description of Transfer and Competent Supervisory Authority), Annex II (Technical and Organizational Measures) and Annex III (List of Sub-processors) of the SCCs are completed by Annex 1, Schedule 2 and Schedule 3 to the DPA respectively.

5.3. UK Addendum

For transfers of Personal Data subject to the UK GDPR, the SCCs as incorporated under Section 5.2 apply as amended by the UK Addendum, which is incorporated into the DPA by reference. Table 1 of the UK Addendum is completed with the party details in Annex 1; Table 2 is completed by Section 5.2; Table 3 is completed by Annex 1, Schedule 2 and Schedule 3; and in Table 4, neither party may end the UK Addendum as set out in its Section 19.

5.4. Switzerland

For transfers of Personal Data subject to the Swiss FADP, the SCCs as incorporated under Section 5.2 apply with the following changes: references to the GDPR are to be read as references to the Swiss FADP; the competent supervisory authority under Clause 13 is the Swiss Federal Data Protection and Information Commissioner; references to "Member State" in Clause 18(c) shall not prevent Data Subjects in Switzerland from bringing claims in their place of habitual residence; and the SCCs also protect the data of legal entities to the extent the Swiss FADP does.

5.5. Onward Transfers to Sub-processors

Pelcro's Sub-processors are based in the United States. Pelcro ensures that every onward transfer of EU Personal Data to a Sub-processor is protected by the Standard Contractual Clauses (together with the UK Addendum for Personal Data subject to the UK GDPR) and, where the Sub-processor is certified, by the EU-U.S. Data Privacy Framework and its UK Extension and Swiss-U.S. counterpart. The transfer mechanism for each Sub-processor is listed at https://www.get.pelcro.com/subprocessors.

5.6. Conflict and Updated Clauses

If there is any conflict between the DPA and the Standard Contractual Clauses or the UK Addendum, the Standard Contractual Clauses or the UK Addendum shall prevail. If the European Commission, the UK Government or the Swiss authorities adopt new or amended standard contractual clauses, the Parties agree that the most up-to-date version shall apply from the date it becomes effective, completed with the information in the Schedules and Annex 1 to the DPA.

5.7. Government Access Requests

  • The Parties warrant that they have no reason to believe that the laws in the third country of destination applicable to the processing of the EU Personal Data by the Data Importer, including any requirements to disclose personal data or measures authorising access by public authorities, prevent the Data Importer from fulfilling its obligations under the Standard Contractual Clauses. This is based on the understanding that laws that respect the essence of the fundamental rights and freedoms and do not exceed what is necessary and proportionate in a democratic society to safeguard one of the objectives listed in Article 23(1) GDPR, are not in contradiction with the Standard Contractual Clauses.

  • The Parties declare that as related to the transfer, they have taken due account in particular of the following elements: the specific circumstances of the transfer, including the content and duration of the contract; the scale and regularity of transfers; the length of the processing chain, the number of actors involved and the transmission channels used; the type of recipient; the purpose of processing; the nature of the personal data transferred; any relevant practical experience with prior instances, or the absence of requests for disclosure from public authorities received by the Data Importer for the type of data transferred; the laws of the third country of destination relevant in light of the circumstances of the transfer, including those requiring to disclose data to public authorities or authorising access by such authorities, as well as the applicable limitations and safeguards; any safeguards in addition to those under the Standard Contractual Clauses, including the technical and organisational measures applied during transmission and to the processing of the personal data in the country of destination.

  • Data Importer shall implement and maintain a documented procedure for reviewing and responding to Government Authority Requests. Such procedure shall require that Data Importer: to the fullest extent permitted by law, immediately notify Data Exporter, in writing, of any such Government Authority Request and cooperate with Data Exporter in responding to such request; scrutinize any such Government Authority Request to determine whether the request is valid, legally binding and lawful and reject or contest any request that is not valid, legally binding and lawful; and ensure that the EU Personal Data disclosed or to which access is provided is proportionate and limited to the minimum amount strictly necessary for the purpose of complying with the Government Authority Request. Data Importer shall, to the fullest extent permitted by applicable law, remove any information prior to disclosure or access that would allow an individual to be directly identified from the data disclosed or to which access is provided.

  • Data Importer shall maintain a written record of all Government Authority Requests. Such record shall include details of (i) the government authorities making the requests or demands, (ii) the number of requests or demands received and how Data Importer responded to such requests or demands, (iii) the types of Personal Data that Data Importer was required to provide in connection with such requests or demands, and (iv) the number of individuals to whom such requests or demands are related. To the extent permitted by applicable law, Data Importer shall make aggregated information from such records available to Data Exporter upon request.

6. Notices

All notices and communications given under the DPA shall be governed by the notice provisions in the online Terms and Conditions or the offline agreement you may have entered into with Pelcro, as applicable.

7. Governing Law and Jurisdiction

The governing law and jurisdiction of the DPA shall be the same as that in the online Terms and Conditions or the offline agreement you may have entered into with Pelcro, as applicable.

The DPA (which includes the Schedules and Annex 1) has been entered into on the date of the last signature below.

Signed for and on behalf of PELCRO Inc:

  • Name: _________________

  • Position: _________________

  • Date: _________________

Signed for and on behalf of CUSTOMER:

  • Name: _________________

  • Position: _________________

  • Date: _________________

8. Contacting Us

If you have any questions or concerns, you may contact us at legal@pelcro.com

Schedule 1: Details of Processing

Duration of the Processing: The duration of data Processing shall be for the term agreed between Customer and Pelcro in the online Terms and Conditions or the offline agreement, as applicable.

Nature and purpose of the Processing: The scope and purpose of Processing of the data subjects' Personal Data is:

  • to provide, maintain and facilitate the Services as well as to ensure Services performance, to upgrade and to improve the functionality of the Services;

  • to provide AI features of the Services, including processing through Amazon Bedrock with inference restricted to AWS regions in the United States;

  • to comply with regulatory requirements, as applicable;

  • to secure (establish, investigate or defend) any legal claims that may arise due to the Services.

Categories of data subjects: Customer may submit Personal Data in the course of using the Purchased Services, the extent of which is determined and controlled by the Customer in its sole discretion, and which may include, but is not limited to Personal Data relating to the following categories of Data Subjects:

  • Customer employees, contractors, collaborators, applicants, trainees, directors and others whose Personal Data is shared by a Customer in the context of the services provided by Pelcro.

  • End users of the Services who access Customer platforms hosted by the Services.

Categories of Personal Data: The Personal Data transferred concern the following categories of data in relation to the categories of data subjects described above:

  • Identifiers: first and last name, username and account identifiers;

  • Contact information: business and personal email address, phone number, company name and business address;

  • Billing and shipping address;

  • Payment details: last 4 digits of the credit card number;

  • Subscription and transaction history: plans, orders, invoices, payments, renewals and cancellations;

  • Reading and paywall activity: articles viewed, meter counts and content access;

  • Technical data: IP address, device and browser information;

  • Account credentials: passwords, stored in hashed form;

  • Support communications: messages exchanged with Customer or Pelcro support;

  • Data submitted to AI features: content of End User interactions with AI features of the Services.

Frequency of the transfer: continuous, for the duration of the Services.

Retention: as set out in Section 2.7.

Special categories of data (if appropriate): The Personal Data transferred concern the following special categories of data (please specify):

  • Customer may not submit special categories of data to the Services. For the sake of clarity special categories of data are Personal Data with information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade-union membership, and the processing of genetic data, biometric data, data concerning health or data concerning a natural person’s sex life or sexual orientation.

Schedule 2: Security and Organizational Measures

Pelcro will maintain administrative, organizational, physical, and technical safeguards for protection of the security, confidentiality, availability and integrity of Personal Data uploaded to the Services.

Pelcro will not materially decrease the overall security of the Services during a Subscription Term. You can find a list of the Security and Organizational measures at https://www.get.pelcro.com/security.

Schedule 3: List of Subprocessors

Pelcro publishes the list of Sub-Processors contracted to process all Personal Data on its website at https://www.get.pelcro.com/subprocessors.

Annex 1: Standard Contractual Clauses Annexes

Annex I.A: List of Parties

Data exporter:

  • Name: Customer, as specified in the online Terms and Conditions or the offline agreement

  • Address and contact details: as specified in the online Terms and Conditions or the offline agreement

  • Activities relevant to the transfer: use of the Services as described in Schedule 1

  • Role: Controller (Module Two) or Processor (Module Three)

Data importer:

  • Name: Pelcro Inc., a corporation incorporated in Canada

  • Address: 3555 Côte-des-Neiges, #1810, Montreal, Quebec, Canada

  • Contact: legal@pelcro.com, +1 888-566-5317

  • Activities relevant to the transfer: provision of the Services as described in Schedule 1

  • Role: Processor

Signature and date: as set out in Section 7 of the DPA. Where the DPA is accepted online, acceptance of the DPA constitutes signature of this Annex.

Annex I.B: Description of Transfer

The categories of Data Subjects, categories of Personal Data, special categories of data, frequency of the transfer, nature and purpose of the Processing, and retention period are described in Schedule 1. Transfers to Sub-processors are for the purposes described on the list of Sub-processors in Schedule 3, for the duration of the Services.

Annex I.C: Competent Supervisory Authority

The competent supervisory authority is determined in accordance with Clause 13 of the Standard Contractual Clauses and Section 5.2 of the DPA; for the UK, it is the Information Commissioner's Office; and for Switzerland, it is the Federal Data Protection and Information Commissioner.

Annex II: Technical and Organizational Measures

The technical and organizational measures implemented by the data importer are described in Schedule 2.

Annex III: List of Sub-processors

The list of Sub-processors authorized by Customer is described in Schedule 3.