Data Processing Addendum

This Data Processing Addendum (“DPA”) forms part of the End User License Agreement or Terms of Use available at www.42gears.com or such other location as the Terms of Use/EULA may be posted from time to time as applicable (, the “Agreement”), entered into by and between the (“Customer”) and 42Gears Mobility Systems Private Limited and its subsidiaries and Affiliates(“42Gears”), pursuant to which Customer has accessed 42Gears Services as defined in the applicable Agreement. The purpose of this Data Processing Addendum is to reflect the parties agreement with regard to the processing of personal data in accordance with the requirements of General Data Protection Regulation and California Consumer Protection Act as defined below.

The Data Processing Addendum will not apply where 42Gears act as Data Controller. This Data Processing Addendum applies when Customer Data is processed by 42Gears. In this context 42Gears will act as a “processor” to Customer who may act either as a “Controller” or “Processor” with respect to the Customer Data (as each term is defined below in accordance with GDPR)

1. Definitions:

a) Agreement: means the agreement between 42Gears and the Customer whether in any written or electronic form to provide Service to the Customers.
b) Data Controller: means natural or legal entity that determines the purpose and means for processing data.
c) Data Breach: a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed in connection with the provision of services to Customers by 42Gears.
d) Personal Data: Personal data is the information relating to an individual who can be directly or indirectly identified from that data. Identification can be through reference to the information itself, or in conjunction with any other information in our possession or likely to come into such possession.
e) Data Processor: means any natural or legal entity who processes the personal data on behalf of the data controller.
f) Services: any cloud services or customer support provided by 42Gears to the Customers pursuant to this Agreement.
g) Sub-Processor: means any third party service provider that 42Gears may engage to process personal data of its Customers pursuant to this Agreement.
h) "ISO 27001 Certification means ISO/IEC 27001:2019 certification or a comparable certification for the Processor Services.
i) “California Consumer Privacy Act of 2018” or “CCPA” means Assembly Bill 375 of the California House of Representatives, an act to add Title 1.81.5 (commencing with Section 1798.100) to Part 4 of Division 3 of the Civil Code, relating to privacy and approved by the California Governor on June 28, 2018;
j) Standard Contractual Clauses: means ANNEXURE 1, attached to and forming part of this Data Processing Addendum pursuant to the European Commision Decision of 5th January 2010 on Standard Contractual Clauses for the transfer of personal data to processors established in third countries under Directive 95/46/EC.

2. Objectives of Data Processing:

  1. 42Gears undertakes to process personal data on behalf of the Customer in accordance with the conditions laid down in this Data Processing Addendum . The processing will be executed exclusively within the framework of the Addendum, and for all such purposes as may be agreed to subsequently.
  2. 42Gears shall refrain from making use of the personal data for any purpose other than as specified by the Customer. The Customer will inform 42Gears of any such purposes which are not contemplated in this Data Processing Addendum .
  3. All personal data processed on behalf of the Customer shall remain the property of the Customer and/or the relevant Data subjects.
  4. 42Gears shall not, on its behalf, make any unilateral decisions regarding the processing of the personal data other than the purpose as set out in the Agreement.

3. 42Gears obligations to process Personal Data:

  1. 42Gears shall warrant compliance with the applicable data protection laws and regulations governing the protection of personal data, including the General Data Protection Regulations which take effect from 25May, 2018.
  2. 42Gears shall furnish to the Customer promptly on request, with details regarding the measures it has adopted to comply with its obligations under this Data Processing Addendum .

The obligations arising under the terms of this Data Processing Addendum also apply to each Sub-Processor who processes personal data under the instruction of 42Gears. Without limiting the generality of the foregoing, to the extent the California Consumer Privacy Act of 2018, as amended, Cal. Civ. Code § 1798.100 et.seq. (“CCPA”), applies to any Personal Data, such Personal Data will be disclosed by Customer to 42Gears for a ‘business purpose’ and 42Gears will act as Customer’s ‘service provider’, as such terms are defined under CCPA. 42Gears will not retain, use or disclose Personal Data for a commercial or any other purpose other than for the specific purpose of providing the Se

4. Allocation of Responsibility:

  1. 42Gears shall only be responsible for processing the personal data under this Data Processing Addendum , in accordance with the Customer’s instructions and under the (ultimate) responsibility of the Customer. 42Gears is explicitly not responsible for other processing of personal data, including but not limited to processing for purposes that are not reported by the Customer to 42Gears.
  2. Customer represents and warrants that it has express consent and/or a legal basis to process the relevant personal data. Furthermore, the Customer represents and warrants that the contents are not unlawful and do not infringe This document is proprietary and confidential. No part of this document may be disclosed in any manner to a third party without the prior written consent of 42Gears Mobility Systems. Version 2 September 2020 any rights of a third party. In this context, the Customer indemnifies 42Gears of all claims and actions of third parties related to the processing of personal data without express consent and/or legal basis under this Data Processing Addendum

5. Sub-Processors:

  1. 42Gears is authorised within the framework of the Agreement to engage Subprocessors to provide certain services on its behalf. Customer consents to 42Gears engaging Sub-processors to process Personal Data under the Agreement. Upon written request of the Customer, 42Gears shall inform the Customer about the third party/parties engaged.
  2. 42Gears shall in any event ensure that the Sub-processor will be obliged to agree in writing to the similar substantial duties that are agreed between the Customer and 42Gears as set out in this Data Processing Addendum.
  3. 42Gears agrees (i) to provide prior notice to Customer of any new appointment or a replacement of a Sub-processor to process Personal Data and (ii) if Customer objects to a new Sub-processor on reasonable data protection grounds within ten (10) days of receiving the notice, to discuss the Customer those concerns in good faith with a view to achieve a resolution.

6. Duty to Report Security Incident:

  1. In the event of a data breach or a security incident, 42Gears shall, to the best of its ability, notify the Customer thereof without undue delay, after which the Customer shall determine whether or not to inform the Data subjects and/or the relevant regulatory authority(ies). This duty to report applies irrespective of the impact of the leak.
  2. 42Gears will endeavour that the furnished information is complete, correct and accurate
  3. Under the GDPR or under any applicable law and/or regulation, 42Gears shall cooperate in notifying the relevant authorities and/or Data subjects. However, 42Gears obligation to notify or respond is not an acknowledgment by 42Gears of any fault or liability with respect to the Security incident.
  4. Notification(s) of Security Incidents, if any, will be delivered to one or more of Customer’s administrators by any means 42Gears selects, including via email. It is Customer’s sole responsibility to ensure Customer’s administrators maintain accurate contact information on 42Gears SureMDM console and secure transmission at all times

7. Security:

  1. 42Gears will endeavour to take adequate technical and organisational measures against loss or any form of unlawful processing (such as unauthorised disclosure, deterioration, alteration or disclosure of personal data) in connection with the processing of personal data under this Data Processing Addendum.
  2. 42Gears will endeavour to ensure that the security measures are of a reasonable level, having regard to the sensitivity of the personal data and the costs related to the security measures.
  3. The Customer will assure its own security measures for secure transfer of personal data to 42Gears. 42Gears will adopt appropriate security measures to ensure data security while transferring the personal data back to the Customer.
  4. To evaluate and ensure the continued effectiveness of the security measures, 42Gears will maintain the ISO-27001 Certification and restricts its personnel from processing Personal Data without authorization (unless required to so by applicable law) and will ensure that any person authorized by 42Gears to process Personal Data is subject to an obligation of confidentiality

8. Response to Data Subjects:

Where a Data subject submits a request to 42Gears to exercise any of its rights under the General Data Protection Regulation or any applicable law/regulation, 42Gears will forward the request to the Customer and the request will then be dealt with by the Customer, 42Gears will not respond directly to such request without obtaining the prior approval of the Customer. If 42Gears is required to respond to the Data Subject Request directly, it will promptly notify the Customer of such request, unless 42Gears is prohibited to do so under any applicable law/regulation.

9. Data Centre:

42Gears uses AWS (Amazon Web Services) to host the services. Information about the locations of the data centre is available at https://aws.amazon.com/security/?nc1=f_cc or as updated by Amazon from time to time.

10. Audit:

  1. In order to confirm compliance with this Data Processing Addendum , the Customer shall be at liberty to conduct an audit by assigning an independent third party who shall be obliged to observe confidentiality in this regard. Any such audit will follow 42Gears reasonable security requirements, and will not interfere unreasonably with 42Gears business activities.
  2. The costs of the audit will be borne by the Customer.
  3. 42Gears may object to any third party audit, if the auditor is, in 42Gears's reasonable opinion, not suitably qualified or independent, a competitor of 42Gears or otherwise manifestly unsuitable. Any such This document is proprietary and confidential. No part of this document may be disclosed in any manner to a third party without the prior written consent of 42Gears Mobility Systems. Version 2 September 2020 objection by 42Gears will require the Customer to appoint another auditor or conduct the audit itself.

Nothing in this Data Protection Addendum will require 42Gears either to disclose Customer or its third-party auditor or to allow Customer or its third-party auditor to access:

a. any data of any other Customer of 42Gears and its any entity
b. 42Gears internal accounting or financial information.
c. any trade secret of 42Gears
d. any information that, in 42Gears reasonable opinion, could (A) compromise the security of any 42Gears systems or premises or (B) cause 42Gears to breach any of its obligations under the Data Protection Legislation or its security and/or privacy obligations to Customer or any third party; or
e. any information that Customer or its third-party auditor seeks to access for any reason other than the good faith fulfilment of Customer's obligations under the Data Protection Legislation.

11. Duration and Termination:

  1. This Data Processing Addendum is entered into for the duration set out in the Agreement, and in the absence thereof, for the duration of the cooperation between the Parties.
  2. The Data Processing Addendum may not be terminated in the interim.
  3. This Data Processing Addendum may only be amended by the Parties subject to mutual consent
  4. 42Gears shall provide its full cooperation in amending and adjusting this Data Processing Addendum in the event of new legislation.

12. Customer Requests:

42Gears shall comply with the applicable data protection laws and regulations. For the avoidance of doubt we will:

  1. Provide support to Customer at their request to assess the impact of our services on their privacy (for example, through assisting Customer with a Data Protection Impact Assessment);
  2. Provide support to customers in responding to requests from data subjects to exercise their rights under the EU General Data Protection Regulation (GDPR).

13. Transparency:

42Gears has documented its processing and publishes this in the privacy notice. This can be found on the 42Gears website, or provided at your request.

14. Miscellaneous :

In the case of any inconsistency between documents and the appendices thereto, the following order of priority will apply:

  1. This Data Processing Addendum ;
  2. The Agreement;
  3. Additional conditions, where applicable.

ANNEXURE 1

STANDARD CONTRACTUAL CLAUSES

Clause 1

Definitions
For the purposes of the Clauses:
(a) ‘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 ;
(b) ‘the data exporter’ means the controller who transfers the personal data;
(c) ‘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;
(d) ‘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;
(e) ‘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;
(f) ‘technical and organisational security measures’ means those measures aimed at protecting
personal data against accidental or unlawful destruction or accidental loss, alteration,
unauthorised 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:
(a) 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;
(b) 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;
(c) that the data importer will provide sufficient guarantees in respect of the technical and
organisational security measures specified in Appendix 2 to this contract;
(d) 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, unauthorised 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;
(e) that it will ensure compliance with the security measures;
(f) 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
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transmitted to a third country not providing adequate protection within the meaning of
Directive 95/46/EC;
(g) to forward any notification received from the data importer or any sub-processor 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;
(h) 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 sub-processing 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;
(i) that, in the event of sub-processing, the processing activity is carried out in accordance with
Clause 11 by a sub-processor 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
(j) that it will ensure compliance with Clause 4(a) to (i).

Clause 5

Obligations of the data importer
The data importer agrees and warrants:
(a) 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;
(b) 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;
(c) that it has implemented the technical and organisational security measures specified in
Appendix 2 before processing the personal data transferred;
(d) that it will promptly notify the data exporter about:
(i) 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;
(ii) any accidental or unauthorised access; and
(iii) any request received directly from the data subjects without responding to that request,
unless it has been otherwise authorised to do so;
(e) 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;
(f) 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;
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(g) to make available to the data subject upon request a copy of the Clauses, or any existing
contract for sub-processing, 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;
(h) that, in the event of sub-processing, it has previously informed the data exporter and
obtained its prior written consent;
(i) that the processing services by the sub-processor will be carried out in accordance with
Clause 11;
(j) to send promptly a copy of any sub-processor 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 sub-processor 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 sub-processor 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 sub-processor 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 sub-processor 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
sub-processor agrees that the data subject may issue a claim against the data sub-processor 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 sub-processor 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:
(a) to refer the dispute to mediation, by an independent person or, where applicable, by the
supervisory authority;
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(b) 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 sub-processor, 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 sub-processor preventing the conduct of an audit of the data importer, or
any sub-processor, 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 sub-processor which
imposes the same obligations on the sub-processor as are imposed on the data importer under
the Clauses. Where the sub-processor 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 sub-processor’s obligations under such agreement.
2. The prior written contract between the data importer and the sub-processor 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
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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 sub-processor shall be limited to its own processing operations under
the Clauses.
3. The provisions relating to data protection aspects for sub-processing 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 sub-processing 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 sub-processor 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 sub-processor 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

Data Exporter
The Data Exporter is a customer of 42Gears Products or Services as part of its Unified
Endpoint Management solution business.
Data Importer
The Data Importer is 42Gears Mobility Systems Private Limited and its affiliates and
subsidiaries, an enterprise mobility solutions.
Data subjects
The Personal Data transferred concern the following categories of Data Subjects:
42Gears may process any data inputted by authorised users of our Products or Services.
Primarily, this will relate to living individuals who are:
● users who are authorised by Data Exporter to use the services
● employees, agents, contractors, and contacts of the Data Exporter
● prospects, customers and clients, business partners and vendors of the Data Exporter
● advisors and professional experts of the Data Exporter
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● employees, agents, contractors, and contacts of the Data Exporter’s prospects,
customers and clients, business partners, vendor, advisors and professional experts.

Categories of data

The Personal Data transferred concern the following categories of data:
42Gears may Process any data inputted by authorised users at the time of login in our Products
or Services.
For further details regarding what all data we collect, please refer 42Gears Privacy Notice
https://www.42gears.com/privacy-policy/

Processing Operations

The Personal Data transferred will be subject to the following basic Processing activities:
The Processing activity of 42Gears will include the performance of the services pursuant to the
EULA and Terms of Use with us.

Appendix 2 to the Standard Contractual Clauses

Description of the technical and organisational security measures implemented by
42Gears in accordance with Clauses 4(d) and 5(c) (or document/legislation attached):
Our security practices are described in our Security and Compliance Standards available at
https://www.42gears.com/security-and-compliance/ (or at such other URL as may be notified to
the Data Exporter from time to time).

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Last Updated: September 15, 2020