This Data Processing addendum ("Agreement"), between you as the Customer, (herein after referred as the "DATA CONTROLLER") acting on its own behalf; and Adonis AS (hereinafter referred as the “DATA PROCESSOR") acting on its own behalf.
The terms used in this Agreement shall have the meanings set forth in this Addendum. Terms not otherwise defined here in shall have the meaning given to them in theMaster Agreement. Except as modified below, the terms of the Master Agreement shall remain in full force and effect.
The MasterAgreement provides the instruction for processing, described in this addendum, and personal data shall only be processed for the purposes of the Master Agreement.
The parties hereby agree that the terms and conditions set out below shall be added as an Addendum to the Master Agreement, which will in any case of conflict take precedence over any Software License Agreement between the parties.
In thisAgreement, the following terms shall have the meanings set out below and cognate terms shall be construed accordingly:
"Authorized Sub-processors" means (a) those Sub-processors set out in Annex B (Authorized Transfers of Controller Personal Data); and (b) any additional Sub-processors consented to in writing by Controller in accordance with Sub processing section.
"Sub-processor" means any Data Processor (including any third party) appointed by the Processor to process Controller Personal Data on behalf of the Controller.
"Process/Processing/Processed", "DataController", "Data Processor", "Data Subject","Personal Data", "Special Categories of Personal Data" and any further definition not included under this Agreement, or the Master Agreement shall have the same meaning as in EU General Data Protection Regulation2016/679 of the European Parliament and of the Council("GDPR").
“Data Protection Laws” means EU General Data Protection Regulation 2016/679 of the European Parliament and of the Council ("GDPR") as well as any local data protection laws.
“Erasure" means the removal or destruction of Personal Data such that it cannot be recovered or reconstructed.
"EEA" means the European Economic Area.
"Thirdcountry" means any country outside EU/EEA, except where that country is the subject of a valid adequacy decision by the European Commission on the protection of Personal Data in Third Countries.
"Controller Personal Data" means the data described in Annex A and any other Personal Data processed by Processor on behalf of the Controller pursuant to orin connection with the Master Agreement.
"Personal Data Breach" means a breach of leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Controller Personal Data transmitted, stored or otherwise processed.
"Services" means the services to be supplied by the Processor to the Controller pursuant to the Master Agreement.
“Products” means the products to be supplied by the Processor to the Controller pursuant to the Master Agreement.
"Standard Contractual Clauses" means the standard contractual clauses for the transfer of personal data to Processors established in third countries, as approved by theEuropean Commission, or any set of clauses approved by theEuropean Commission which amends, replaces or supersedes these.
"Work-related activities" does not contain the physical location of a person. It means the possibility to track for what dates a person is sailing ,on leave, on training, etc.
1. These Contractual Clauses (the Clauses) set out the rights and obligations of the DATACONTROLLER and the DATA PROCESSOR, when processing personal data on behalf of the DATA CONTROLLER.
2. The Clauses have been designed to ensure the parties’ compliance with Article28(3)of Regulation 2016/679 of the European Parliament and of the Council of 27April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealingDirective95/46/EC (General Data Protection Regulation).
3. In the context of the provision of products and services, the DATA PROCESSOR will process personal data on behalf of the DATA CONTROLLER in accordance with theClauses.
4. The Clauses shall take priority over any similar provisions contained in other agreements between the parties.
5. Four appendices are attached to the Clauses and form an integral part of the Clauses.
6. Appendix A contains details about the processing of personal data, including the purpose and nature of the processing, type of personal data, categories of data subject and duration of the processing.
7. Appendix B contains the DATA CONTROLLER’s conditions for the DATA PROCESSOR’s use of sub-processors and a list of sub-processors authorised by the DATA CONTROLLER.
8. Appendix C contains the DATA CONTROLLER’s instructions with regards to the processing of personal data, the minimum security measures to be implemented by the DATA PROCESSOR and how audits of the DATA PROCESSOR and any sub-processors are to be performed.
9. Appendix D contains provisions for other activities which are not covered by theClauses.
10. The Clauses along with appendices shall be retained in writing, including electronically, by both parties.
11. TheClauses shall not exempt the DATA PROCESSOR from obligations to which the DATA PROCESSOR is subject pursuant to the General Data Protection Regulation (theGDPR) or other legislation.
1. The DATA CONTROLLER is responsible for ensuring that the processing of personal data takes place in compliance with the GDPR (see Article 24 GDPR), the applicable EU or Member State[1] data protection provisions and the Clauses.
2. The DATA CONTROLLER has the right and obligation to make decisions about the purposes and means of the processing of personal data.
3. The DATA CONTROLLER shall be responsible, among other, for ensuring that the processing of personal data, which the DATA PROCESSOR is instructed to perform, has a legal basis. .
1. The data processor shall process personal data only on documented instructions from the data controller, unless required to do so by Union or Member State law to which the processor is subject. Such instructions shall be specified in appendices A and C. Subsequent instructions can also be given by the data controller throughout the duration of the processing of personal data, but such instructions shall always be documented and kept in writing, including electronically, in connection with the Clauses.
2. The data processor shall immediately inform the data controller if instructions given by the data controller, in the opinion of the data processor, contravene the GDPR or the applicable EU or Member State data protection provisions.
1. The data processor shall only grant access to the personal data being processed on behalf of the data controller to persons under the data processor’s authority who have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality and only on a need to know basis. The list of persons to whom access has been granted shall be kept under periodic review. On the basis of this review, such access to personal data can be withdrawn, if access is no longer necessary, and personal data shall consequently not be accessible anymore to those persons.
2. The data processor shall at the request of the data controller demonstrate that the concerned persons under the data processor’s authority are subject to the above mentioned confidentiality.
1. Article 32 GDPR stipulates that, 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 DATA CONTROLLER and DATA PROCESSOR shall implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk.
The DATA CONTROLLER shall evaluate the risks to the rights and freedoms of natural persons inherent in the processing and implement measures to mitigate those risks. Depending on their relevance, the measures may include the following:
a. Pseudonymization and encryption of personal data;
b. the ability to ensure ongoing confidentiality, integrity, availability and resilience of processing systems and services;
c. the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident;
d. a process for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing.
2. According to Article 32 GDPR, the DATA PROCESSOR shall also – independently from the DATA CONTROLLER – evaluate the risks to the rights and freedoms of natural persons inherent in the processing and implement measures to mitigate those risks. To this effect, the DATA CONTROLLER shall provide the DATA PROCESSOR with all information necessary to identify and evaluate such risks.
3. Furthermore, the DATA PROCESSOR shall assist the DATA CONTROLLER in ensuring compliance with the DATA CONTROLLER’s obligations pursuant to Articles 32 GDPR, by inter alia providing the DATA CONTROLLER with information concerning the technical and organizational measures already implemented by the DATA PROCESSOR pursuant to Article 32 GDPR along with all other information necessary for the DATA CONTROLLER to comply with the DATA CONTROLLER’s obligation under Article 32 GDPR.
If subsequently– in the assessment of the DATA CONTROLLER – mitigation of the identified risks require further measures to be implemented by the DATAPROCESSOR, than those already implemented by the DATA PROCESSOR pursuant to Article 32 GDPR, the DATA CONTROLLER shall specify these additional measures to be implemented in Appendix C.
1. The DATA PROCESSOR shall meet the requirements specified in Article 28(2) and (4)GDPR in order to engage another processor (a sub-processor).
2. The DATA PROCESSOR shall therefore not engage another processor (sub-processor) for the fulfilment of the Clauses without the prior written authorization of the DATA CONTROLLER, either general or specific.
3. The DATA PROCESSOR shall engage sub-processors solely with the prior authorization of the DATA CONTROLLER. The DATA PROCESSOR shall submit the request for specific authorization at least without undue delay prior to the engagement of the concerned sub-processor, unless a general authorization has already been given. The list of sub-processors already authorized by the DATA CONTROLLER can be found in Appendix B.
4. Where the DATA PROCESSOR engages a sub-processor for carrying out specific processing activities on behalf of the DATA CONTROLLER, the same data protection obligations as set out in the Clauses shall be imposed on that sub-processor by way of a contract or other legal act under EU or Member State law, in particular providing sufficient guarantees to implement appropriate technical and organizational measures in such a manner that the processing will meet the requirements of the Clauses and the GDPR.
The DATAP ROCESSOR shall therefore be responsible for requiring that the sub-processor at least complies with the obligations to which the DATA PROCESSOR is subject pursuant to the Clauses and the GDPR.
5. A copy of such a sub-processor agreement and subsequent amendments shall – at the DATA CONTROLLER’s request – be submitted to the DATA CONTROLLER, thereby giving the DATA CONTROLLER the opportunity to ensure that the same data protection obligations as set out in the Clauses are imposed on the sub-processor. Clauses on business related issues that do not affect the legal data protection content of the sub-processor agreement, shall not require submission to the DATA CONTROLLER.
6. The DATA PROCESSOR shall agree a third-party beneficiary clause with the sub-processor where – in the event of bankruptcy of the DATA PROCESSOR – the DATA CONTROLLER shall be a third-party beneficiary to the sub-processor agreement and shall have the right to enforce the agreement against the sub-processor engaged by the DATA PROCESSOR, e.g. enabling the DATA CONTROLLER to instruct the sub-processor to delete or return the personal data.
7. If the sub-processor does not fulfil his data protection obligations, the DATAP ROCESSOR shall remain fully liable to the DATA CONTROLLER as regards the fulfilment of the obligations of the sub-processor. This does not affect the rights of the data subjects under the GDPR – in particular those foreseen in Articles 79 and 82 GDPR – against the DATA CONTROLLER and the DATA PROCESSOR, including the sub-processor.
1. Any transfer of personal data to third countries or international organizations by the DATA PROCESSOR shall only occur on the basis of documented instructions from the DATA CONTROLLER and shall always take place in compliance with Chapter V GDPR.
2. In case transfers to third countries or international organizations, which the DATA PROCESSOR has not been instructed to perform by the DATA CONTROLLER, is required under EU or Member State law to which the DATA PROCESSOR is subject, the DATA PROCESSOR shall inform the DATA CONTROLLER of that legal requirement prior to processing unless that law prohibits such information on important grounds of public interest.
3. Without documented instructions from the DATA CONTROLLER, the DATA PROCESSOR therefore cannot within the framework of the Clauses, other than with respect to those recipients in Third Countries (if any) listed in Annex B (Authorized Transfers of Controller Personal Data):
a. transfer personal data to a DATA CONTROLLER or a DATA PROCESSOR in a third country or in an international organization
b. transfer the processing of personal data to a sub-processor in a third-country
c. have the personal data processed by the DATA PROCESSOR in a third country
4. The DATA CONTROLLER’s instructions regarding the transfer of personal data to a third country including, if applicable, the transfer tool under Chapter V GDPR on which they are based, shall be set out in Appendix C.6.
5.The Clauses shall not be confused with standard data protection clauses within the meaning of Article 46 (2) (c) and (d) GDPR, and the Clauses cannot be relied upon by the parties as a transfer tool under Chapter V GDPR.
1. Taking into account the nature of the processing, the DATA PROCESSOR shall assist the DATA CONTROLLER by appropriate technical and organizational measures, insofar as this is possible, in the fulfilment of the DATA CONTROLLER’s obligations to respond to requests for exercising the data subject’s rights laid down in Chapter III GDPR.
This entails that the DATA PROCESSOR shall, in so far as this is possible, assist the DATA CONTROLLER in the DATA CONTROLLER’s compliance with:
a. the right to be informed when collecting personal data from the data subject
b. the right to be informed when personal data have not been obtained from the data subject
c. the right of access by the data subject
d. the right to rectification
e. the right to erasure (‘the right to be forgotten’)
f. the right to restriction of processing
g. notification obligation regarding rectification or erasure of personal data or restriction of processing
h. the right to data portability
i. the right to object
j. the right not to be subject to a decision based solely on automated processing, including profiling
2. In addition to the DATA PROCESSOR’s obligation to assist the DATA CONTROLLER pursuant to Clause 6.4., the DATA PROCESSOR shall furthermore, taking into account the nature of the processing and the information available to the DATA PROCESSOR, assist the DATA CONTROLLER in ensuring compliance with:
a. The DATA CONTROLLER’s obligation to without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to the competent supervisory authority, Datatilsynet, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons;
b. the DATA CONTROLLER’s obligation to without undue delay communicate the personal data breach to the data subject, when the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons;
c. the DATA CONTROLLER’s obligation to carry out an assessment of the impact of the envisaged processing operations on the protection of personal data (a data protection impact assessment);
d. the DATA CONTROLLER’s obligation to consult the competent supervisory authority, Datatilsynet, prior to processing where a data protection impact assessment indicates that the processing would result in a high risk in the absence of measures taken by the DATA CONTROLLER to mitigate the risk.
3.The parties shall define in Appendix C the appropriate technical and organizational measures by which the DATA PROCESSOR is required to assist the DATA CONTROLLER as well as the scope and the extent of the assistance required. This applies to the obligations foreseen in Clause 9.1. and 9.2.
1. In case of any personal data breach, the DATA PROCESSOR shall, without undue delay after having become aware of it, notify the DATA CONTROLLER of the personal data breach.
2. The DATA PROCESSOR’s notification to the DATA CONTROLLER shall, if possible, enable the DATA CONTROLLER to comply with the DATA CONTROLLER’s obligation to notify the personal data breach to the competent supervisory authority, cf. Article33GDPR.
3. In accordance with Clause 9 (2) (a), the DATA PROCESSOR shall assist the DATA CONTROLLER in notifying the personal data breach to the competent supervisory authority, meaning that the DATA PROCESSOR is required to assist in obtaining the information listed below which, pursuant to Article 33(3)GDPR, shall be stated in the DATA CONTROLLER’s notification to the competent supervisory authority:
a. The nature of the personal data including where possible, the categories and approximate number of data subjects concerned and the categories and approximate number of personal data records concerned;
b. the likely consequences of the personal data breach;
c. the measures taken or proposed to be taken by the controller to address the personal data breach, including, where appropriate, measures to mitigate its possible adverse effects.
4. The parties shall define in Appendix D all the elements to be provided by the DATA PROCESSOR when assisting the DATA CONTROLLER in the notification of a personal data breach to the competent supervisory authority.
1. On termination of the provision of personal data processing services, the DATA PROCESSOR shall be under obligation to, within 90 days, delete all personal data processed on behalf of the DATA CONTROLLER and certify to the DATA CONTROLLER that it has done so or return all the personal data to the DATA CONTROLLER and delete existing copies unless Union or Member State law requires storage of the personal data.
The DATA PROCESSOR commits to exclusively process the personal data for the purposes and duration provided for by this law and under the strict applicable conditions.
1. The DATA PROCESSOR shall make available to the DATA CONTROLLER all information necessary to demonstrate compliance with the obligations laid down in Article 28 and the Clauses and allow for and contribute to audits, including inspections, conducted by the DATA CONTROLLER or another auditor mandated by the DATA CONTROLLER.
2. Procedures applicable to the DATA CONTROLLER’s audits, including inspections, of the DATA PROCESSOR and sub-processors are specified in appendices C. 7. and C. 8.
3. The DATA PROCESSOR shall be required to provide the supervisory authorities, which pursuant to applicable legislation have access to the DATA CONTROLLER’s and DATA PROCESSOR’s facilities, or representatives acting on behalf of such supervisory authorities, with access to the DATA PROCESSOR’s physical facilities on presentation of appropriate identification.
1. The parties may agree other clauses concerning the provision of the personal data processing service specifying e.g. liability, as long as they do not contradict directly or indirectly the Clauses or prejudice the fundamental rights or freedoms of the data subject and the protection afforded by the GDPR.
2. The parties agree that this Agreement and the Standard Contractual Clauses shall terminate automatically upon termination of the Master Agreement or expiry or termination of all service contracts entered into by the Processor with the Controller.
3. This Addendum, excluding the Standard Contractual Clauses, shall be governed by the governing law of the Master Agreement for so long as that governing law is the law of a Member State of the European Union.
4. Any breach of this Addendum shall constitute a material breach of the Master Agreement.
5. With regard to the subject matter of this Addendum, in the event of in consistencies between the provisions of this Addendum and any other agreements between the parties, including but not limited to the Master Agreement, the provisions of this Addendum shall prevail with regard to the parties’ data protection obligations for Personal Data of a Data Subject from a Member State of the European Union.
6.Any obligation imposed on the Processor under this Addendum in relation to the Processing of Personal Data shall survive any termination or expiration of thisAddendum.
1. The Clauses shall become effective on the date of both parties’ signature.
2. Both parties shall be entitled to require the Clauses renegotiated if changes to the law or inexpediency of the Clauses should give rise to such renegotiation.
3. The Clauses shall apply for the duration of the provision of personal data processing services. For the duration of the provision of personal data processing services, the Clauses cannot be terminated unless other Clauses governing the provision of personal data processing services have been agreed between the parties.
4. If the provision of personal data processing services is terminated, and the personal data is deleted or returned to the DATA CONTROLLER pursuant to Clause 11.1. and Appendix C.4., the Clauses may be terminated by written notice by either party.
A.1. The purpose of the DATA PROCESSOR’s processing of personal data on behalf of the DATACONTROLLER is:
Delivering products and services in accordance with the Master Agreement.
A.2. The DATA PROCESSOR’s processing of personal data on behalf of the DATA CONTROLLER shall mainly pertain to (the nature of the processing):
Delivering products and services in accordance with the Master Agreement.
A.3. The processing includes the following types of personal data about data subjects:
A.4.Processing includes the following categories of data subject:
A.5. The DATA PROCESSOR’s processing of personal data on behalf of the DATA CONTROLLER may be performed when the Clauses commence.
Processing has the following duration: For the duration of the Master Agreement.
Appendix A
B.1. Approved sub-processors
On commencement of the Clauses, the DATA CONTROLLER authorizes the engagement of the following sub-processors:
For Adonis Support and Consultancy (all customers)
Authorized sub-processor
Processing activity
Location of service center(s)
Adonis Kharkiv LLC
Support operation and service maintenance
Ukraine
Adonis Development and QA LLC
Software development and troubleshooting
Ukraine
Adonis Project LLC
Support operation and service maintenance
Ukraine
Adonis SEA Inc
Support operation and service maintenance
Philippines
AJ`s Consulting Inc
Support operation and service maintenance
USA
Citizen Development Academy Inc
Software development and troubleshooting
USA
The support and consultancy sub-processors will never get transferred data but may have access to data through the hosted systems or access to customer systems.
For Cloud customers
Authorized sub-processor
Processing activity
Location of service center(s)
Microsoft Ireland Operations LTD
ASP usage report and license audit
Ireland/Norway
Microsoft Ireland Operations LTD
Datacenter hosting
Operation and service maintenance
Azure
· West Europe (NL)
· North Europe (IRL)
· West US 2
· East US
· South East Asia
· East Asia
· Other locations may be utilized in agreement with customer
Front Information AS
SMS sending
Norway
Ironstone AS
Operation and service maintenance
Norway
The DATA CONTROLLER shall on the commencement of the Clauses authorise the use of the above-mentioned sub-processors for the processing described for that party. The DATA PROCESSOR shall not be entitled – without the DATA CONTROLLER’s explicit written authorisation– to engage a sub-processor for a ‘different’ processing than the one which has been agreed upon or have another sub-processor perform the described processing.
B.2. Prior notice for the authorisation of sub-processors
Prior notice for the authorization of sub-processors shall be provided without undue delay.
Appendix B
C.1. The subject of/instruction for the processing
The DATAPROCESSOR’s processing of personal data on behalf of the DATA CONTROLLER shall be carried out by the DATA PROCESSOR performing the following:
Processing according to the Master Agreement
C.2.Security of processing
The level of security shall take into account:
Security Management
a. Security policy and procedures: Processor must document a security policy with regard to the processing of personal data.
b. Roles and responsibilities:
• i. Roles and responsibilities related to the processing of personal data is clearly defined and allocated in accordance with the security policy.
• ii. During internal re-organisations or terminations and change of employment, revocation of rights and responsibilities with respective hand-over procedures is clearly defined.
c. Access Control Policy: Specific access control rights are allocated to each role involved in the processing of personal data, following the need-to-know principle.
d. Resource/asset management: Processor shall have a register of the IT resources used for the processing of personal data(hardware, software, and network). A specific person is assigned the task of maintaining and updating the register (e.g. IT officer).
Back-ups
e. Backup and data restore procedures are defined, documented and clearly linked to roles and responsibilities.
f. Backups are given an appropriate level of physical and environmental protection consistent with the standards applied on the originating data.
g. Execution of backups is monitored to ensure completeness.
Access control and authentication
a. An access control system applicable to all users accessing the IT system is implemented. The system allows creating, approving, reviewing and deleting user accounts.
b. When granting access or assigning user roles, the “need-to-know principle” shall be observed in order to limit the number of users having access to personal data only to those who require it for achieving the Processor’s processing purposes.
c. Where authentication mechanisms are based on passwords, Processor requires the password to be at least eight characters long and conform to very strong password control parameters including length, character complexity, and non-repeatability.
d. The authentication credentials (such as user ID and password) shall never be transmitted unprotected over the network
Network/Communication security
a. Whenever access is performed through the Internet, communication is encrypted through cryptographic protocols.
b. Traffic to and from the IT system is monitored through Firewalls and logs.
Security of data at rest
a. Server/Database security
• i. Database and applications servers are configured with restricted permissions.
• ii. Database and applications servers only process the personal data that are actually needed to process in order to achieve its processing purposes.
b. Workstation security:
• i. Anti-virus applications and detection signatures is configured on a regular basis.
• ii. Critical security updates released by the operating system developer is installed regularly.
Data deletion/disposal
c. Software-based overwriting will be performed on media prior to their disposal. In cases where this is not possible (CD’s, DVD’s, etc.) physical destruction will be performed.
d. Shredding of paper and portable media used to store personal data is carried out.
Physical security
The physical perimeter of the IT system infrastructure is not accessible by non-authorized personnel. Appropriate technical measures (e.g. Intrusion detection system) or organizational measures shall be set in place to protect security areas and their access points against entry by unauthorized persons.
Logging and monitoring
Log files are activated, when possible, for systems used for the processing of personal data. They include details about login, logout, modification and deletion.
Incident response and business continuity
a. Incidents handling /Personal data breaches:
• i. An incident response plan with detailed procedures is defined to ensure effective and orderly response to incidents pertaining personal data.
• ii. Processor will report without undue delay to Controller any security incident that has resulted in a loss, misuse or unauthorized acquisition of any personal data.
b. Business continuity: Processor establishes the main procedures and controls to be followed in order to ensure the required level of continuity and availability of the IT system processing personal data (in the event of an incident/personal data breach).
Human resources
c. Confidentiality of personnel: Processor ensures that all employees understand their responsibilities and obligations related to the processing of personal data. Roles and responsibilities are clearly communicated during the preemployment and/or induction process.
d. Training: Processor ensures that all employees are adequately informed about the security controls of the IT system that relate to their everyday work. Employees involved in the processing of personal data are also properly informed about relevant data protection requirements and legal obligations through regular awareness campaigns.
C.3.Assistance to the DATA CONTROLLER
The DATA PROCESSOR shall insofar as this is possible – within the scope and the extent of the Master Agreement – assist the DATA CONTROLLER in accordance with Clause 9.1.and 9.2. by implementing technical and organizational measures.
C.4. Storage period/erasure procedures
Upon termination of the Master Agreement, the DATA PROCESSOR shall either delete or return the personal data in accordance with Clause 11.1., unless the DATA CONTROLLER – after the signature of the contract – has modified the DATACONTROLLER’s original choice. Such modification shall be documented and kept in writing, including electronically, in connection with the Clauses.
Data is deleted when the contract is terminated according to the procedure for return and erasure of customer data.
C.5. Processing location
Processing of the personal data under the Clauses cannot be performed at other locations than the following without the DATA CONTROLLER’s prior written authorization:
Within the Microsoft Azure eco system as well as the sub processors specified in Appendix B.
C.6.Instruction on the transfer of personal data to third countries
If the DATA CONTROLLER does not in the Clauses or subsequently provide documented instructions pertaining to the transfer of personal data to a third country, the DATA PROCESSOR shall not be entitled within the framework of the Clauses to perform such transfer.
The DATA CONTROLLER adheres to the UK Anti Bribery act.
For the relevant parties, the processor also adheres to:
· The Netherlands: Algemeneverordening gegevensbescherming (mei 2018)
· Belgium: De Wet bescherming persoonsgegevens(juli 2018)
· France: RèglementGénéral pour la protection des Données (RGPD)