Data Processing Agreement

1. Introduction

This Data Processing Agreement ("DPA") forms part of the Master Subscription Agreement or other written or electronic agreement between KudosWall and the Customer for the purchase of online services from KudosWall (the "Agreement") to reflect the parties' agreement with regard to the Processing of Personal Data.

By using our services, the Customer enters into this DPA on behalf of itself and, to the extent required under applicable Data Protection Laws, in the name and on behalf of its Authorized Affiliates.

2. Definitions

• "Data Protection Laws": means all laws and regulations, including laws and regulations of the European Union, the European Economic Area and their member states, Switzerland and the United Kingdom, applicable to the Processing of Personal Data under the Agreement.
• "GDPR": means the Regulation (EU) 2016/679 of the European Parliament and of the Council (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.

3. Privacy-First Commitment

KudosWall is designed with a "Privacy by Design" architecture.

4. Processing of Personal Data

KudosWall shall Process Personal Data only for the purposes described in this DPA and in accordance with Customer's documented instructions. Customer instructs KudosWall to Process Personal Data to provide the Services and related technical support.

5. Sub-processors

KudosWall currently uses the following sub-processors to provide the services: