Legal

GENERAL TERMS AND CONDITIONS

CYCLOP TECHNOLOGIES

The French version of this document prevails. This English text is a translation provided for convenience.

1. Identification of the Company

CYCLOP TECHNOLOGIES OÜ (the "Company") is a private limited company under Estonian law (osaühing) registered in the Estonian commercial register (Äriregister) under no. 17628116, whose registered office is located at Sepapaja tn 6, 15551 Tallinn, Estonia.

2. Services offered

The Company offers its customers (the "Customers") a Linux-based operating system, which can be controlled from a PC or through a mobile application synchronised with the PC (together the "Solution") through downloads on the platform www.cyclop-tech.com (the "Platform"), (the "Services").

3. Information on the General Terms and Conditions

Purpose of the General Terms and Conditions

The general terms and conditions (the "General Terms and Conditions") are the sole document governing the contractual relationship between the Company and the Customer and define:

the terms of use of its Services,

the respective obligations of the parties.

Location of the General Terms and Conditions

The Customer can find them through a direct link at the bottom of the Platform pages.

How the General Terms and Conditions are accepted

The Customer accepts the General Terms and Conditions by ticking a box in the registration form. If the Customer does not accept the General Terms and Conditions in their entirety, they cannot access the Services.

They may be supplemented by special conditions which, in the event of a contradiction, prevail over the General Terms and Conditions.

4. Relationship with the general terms and conditions of the payment service provider

All payments made through the Platform are handled by the payment service provider indicated on the Platform (the "Payment Service Provider").

The Customer will contract directly with the Payment Service Provider for the implementation of these payments, by accepting its general terms and conditions through a checkbox on the Platform.

If the Payment Service Provider refuses or terminates the Customer's subscription, the Customer cannot (or can no longer) use the Services.

Conversely, the end of the contractual relationship between the Customer and the Company results in the termination of the Customer's contract with the Payment Service Provider.

In the event of a contradiction between the general terms and conditions of the Payment Service Provider and the General Terms and Conditions, the latter prevail.

The Customer expressly authorises the Company to pass on to the Payment Service Provider all of the Customer's instructions relating to payments made on the Platform.

5. Conditions of access to the Services

(i) The Customer is a natural person with full legal capacity or, failing that, who has obtained the consent of their legal representative, and undertakes to give the Company the e-mail address of their representative so that the Company can contact them, or a legal entity acting through a natural person who has the power or authorisation required to contract in the Customer's name and on its behalf

(ii) The Customer has the status of professional, meaning any natural person or legal entity acting for purposes within the scope of its commercial, industrial, craft, professional or agricultural activity, including when acting in the name or on behalf of another professional.

6. Terms of access to and subscription to the Services

In order to benefit from the Services, the Customer must have hardware and software compatible with the Services, as specified on the Platform. The Customer is invited to read any incompatibility specified on the Platform.

The Customer can access the Services by going directly to the Platform.

To subscribe to the Services, the Customer must fill in the form provided for this purpose on the Platform and give the Company all the information marked as mandatory.

Registration automatically opens an account in the Customer's name (the "Account") which allows the Customer to access the Services using their login and password.

Once the Customer's Account has been created, the Customer may freely create access for users (the "Users") up to the number provided for in the Services subscribed to.

The Customer is solely responsible for creating access for the Users, for setting their access rights and for their personal use of the Platform.

7. Description of the Services

7.1. The Services

Before any subscription, the Customer acknowledges that they can read on the Platform the characteristics of the Services and their constraints, in particular technical ones.

The Customer acknowledges that using the Services requires an internet connection and that the quality of the Services depends on this connection, for which the Company is not responsible.

The Services to which the Customer has subscribed are described on the Platform.

The Company reserves the right to offer any other Service.

Any request to change the Services subscribed to must be made through a new subscription.

7.2. Additional services

7.2.1. Maintenance

For the duration of the Services, the Customer benefits from maintenance, in particular corrective and evolutive maintenance. In this context, access to the Solution may be limited or suspended.

As regards corrective maintenance, the Company uses its best efforts to provide the Customer with corrective maintenance in order to correct any malfunction or bug identified in the Solution.

As regards evolutive maintenance, the Customer benefits for the duration of the Services from evolutive maintenance, which the Company may carry out automatically and without prior notice, and which includes improvements to the functionalities of the Solution, the addition of new functionalities and/or technical installations used within the Platform (aimed at introducing minor or major extensions).

Updates are carried out throughout the term of these General Terms and Conditions.

Detailed information on the updates carried out is available here.

The Customer must agree to install the updates necessary for the Services to remain compliant, that is, for the Services to continue to be used in accordance with what was agreed between the parties and with what the Customer expected when subscribing.

Access to the Platform may also be limited or suspended for planned maintenance reasons, which may include the corrective and evolutive maintenance operations mentioned above.

7.2.2. Backup, storage and security of data

The Customer is solely responsible for backing up their data, files and settings stored locally on their equipment. The Company provides no hosting, backup or security for such data, its responsibility being limited to the data that it collects and processes itself in the course of the Services, in accordance with its privacy policy.

7.2.3. Hosting

The Company provides, under an obligation of means, the hosting of the Platform, on its own servers or through a professional hosting provider, and on servers located in the territory of the European Union.

The Company acts as a hosting provider for the Content that the Customer puts online. Accordingly, it is not responsible for such Content.

If the Company receives a notification concerning unlawful Content, it will act promptly to remove it or make access to it impossible, and it may take the measures described in the article "Sanctions in the event of breach".

7.2.4. Technical support

The Community edition is offered free of charge and does not entitle the user to any technical support from CYCLOP TECHNOLOGIES. Users of the Community edition may use the online community forum, where mutual assistance between users is organised.

For the paid editions, technical support is available by e-mail. CYCLOP TECHNOLOGIES undertakes to provide a first response within a maximum of two (2) working days from receipt of the request. This is a first-response time: CYCLOP TECHNOLOGIES undertakes to respond, not to resolve, within this time. The actual processing time depends on the nature and complexity of the reported issue.

For the Education edition, additional service packages may be offered.

8. Duration of the subscription to the Services

The Customer subscribes to the Services in the form of a subscription (the "Subscription").

The Subscription starts on the day it is taken out for an initial period indicated on the Platform depending on the plan chosen.

It is tacitly renewed for successive periods of the same length as the initial period (together with the initial period, the "Periods"), from date to date, unless the Subscription is terminated under the conditions of the article "End of the Services".

9. Financial terms of the Company

9.1. Price of the Services

The prices of the Services to which the Customer has subscribed are indicated on the Platform.

If an exchange rate is applied, the exchange fees applicable on the date the price is paid are borne by the Customer. Where applicable, the Customer is solely responsible for paying all bank charges related to the payment of the prices, except for the charges of the Company's bank.

Any Period that has begun is due in full.

The Company is free to offer promotional offers or price reductions.

The Company's prices may be revised at any time under the conditions of the article "Amendment of the General Terms and Conditions".

9.2. Invoicing and payment terms of the Company

The Company sends the Customer one invoice per Period by any appropriate means.

The Subscription is paid by bank card through the secure online payment service specified on the Company's Platform.

Payment is made through the Payment Service Provider indicated on the Platform.

The Customer warrants to the Company that they have the necessary authorisations to use this payment method.

9.3. Consequences of late payment or non-payment

In the event of non-payment or late payment, the Company reserves the right, from the day after the due date shown on the invoice, to:

immediately suspend all or part of the Services in progress until all sums due have been paid in full,

charge, for its benefit, late-payment interest equal to 3 times the legal interest rate, calculated on the amount of the sums not paid by the due date, and a fixed indemnity of 40 euros for recovery costs, without prejudice to additional compensation if the recovery costs actually incurred exceed this amount,

where applicable, declare all sums owed to it by the Customer forfeited as to term and immediately payable.

10. Intellectual property rights

10.1. Intellectual property rights of the Company

The Platform and the elements of the Solution developed by the Company (hereinafter the "Proprietary Elements") are the property of the Company, as are the software, infrastructure, databases and content of any kind (texts, images, visuals, music, logos, trademarks, etc.) that it has developed and that are used on the Solution or the Platform. They are protected by all intellectual property rights or database producers' rights in force.

The licence granted by the Company to the Customer does not entail any transfer of ownership. The Customer benefits from a non-exclusive, personal and non-transferable licence to use the Proprietary Elements of the Solution for the period provided for in the article "Duration of the subscription to the Services".

The Solution also includes third-party software components distributed under a free or open source licence (the "Open Source Components"), the list and applicable licences of which are available on the Solution / on the Platform. The Open Source Components remain governed by their respective licences.

The Solution may finally include, depending on the edition subscribed to by the Customer, proprietary third-party components supplied under the licence of their respective publisher (the "Proprietary Third-Party Components"). The use of these Proprietary Third-Party Components is subject to the general terms and conditions of their publisher, which the Customer undertakes to comply with, the Company granting no warranty in respect of them.

10.2. Reuse of Forum excerpts

The Customer remains the holder of their intellectual property rights in the Content (as defined in the article "Use of the Services") that they publish on the online community forum mentioned in the article "Technical support", where users exchange and help one another (the "Forum").

However, the Customer authorises the Company to quote all or part of the Content published on the Forum in order to promote the Company and its Services, under the following conditions:

the Content is quoted only on the Company's communication media, namely its website and its social media accounts;

the Content is quoted under the Customer's pseudonym or anonymously, at the Customer's choice (anonymously if no choice is made), which they may exercise or change at any time by contacting the Company at the details given in the article "Identification of the Company";

the Company may translate the Content into the languages offered on the Forum and on the Platform, without changing it in a way that alters its meaning;

this authorisation is granted free of charge and gives rise to no remuneration;

it is non-exclusive, valid worldwide and granted for the duration of the Services, extended by three (3) years from their end;

it covers only the rights of reproduction, representation and adaptation (translation) necessary for the use of the Content under the conditions above. The Customer remains free to use their messages elsewhere.

11. Commercial references

The parties may use their respective names, trademarks and logos and refer to their respective platforms, as commercial references, for the duration of their contractual relationship and for 3 years afterwards.

12. Obligations and liability of the Customer

12.1. Provision of information

The Customer undertakes to provide the Company with all the information necessary for subscribing to and using the Services.

12.2. The Customer's Account

The Customer:

warrants that the information given in the form is accurate and undertakes to keep it up to date,

acknowledges that this information constitutes proof of their identity and binds them as soon as it is validated,

is responsible for maintaining the confidentiality and security of their login and password, any access to the Platform using them being deemed to have been made by the Customer.

The Customer must immediately contact the Company at the details given in the article "Identification of the Company" if they find that their Account has been used without their knowledge. They acknowledge that the Company will have the right to take all appropriate measures in such a case.

The Customer is solely responsible for creating access for the Users and for setting their access rights.

12.3. Use of the Services

The Customer is responsible for their use of the Services and for any information they share in this context. They are also responsible for the use of the Services and for any information shared by the Users. They undertake to ensure that the Services are used exclusively by them and/or the Users, who are subject to the same obligations as the Customer in their use of the Services.

The Customer shall not divert the Services to purposes other than those for which they were designed, and in particular to:

engage in any unlawful or fraudulent activity,

undermine public order and morality,

harm third parties or their rights, in any way whatsoever,

breach any contractual, legislative or regulatory provision,

engage in any activity likely to interfere with a third party's computer system, in particular in order to breach its integrity or security,

carry out manoeuvres aimed at promoting their own services and/or sites or those of a third party,

help or encourage a third party to commit one or more of the acts or activities listed above.

The Customer also shall not:

copy, modify or divert any element belonging to the Company or any concept it uses in connection with the Services,

adopt any behaviour likely to interfere with or divert the Company's computer systems or to undermine its computer security measures,

harm the financial, commercial or moral rights and interests of the Company,

market, transfer or give access in any way whatsoever to the Services, to the information hosted on the Platform or to any element belonging to the Company.

By subscribing to the Services, the Customer acknowledges that content of any kind that they publish on the Platform (the "Content") is shared in a spirit of community exchange.

The Customer is responsible for Content of any kind that they share in connection with the Services.

The Customer accepts that Content shared on the Platform is public by default and may be seen by other users of the Platform.

The Customer shall not share any Content (this list is not exhaustive):

that undermines public order and morality (pornographic, obscene, indecent, shocking or unsuitable for a family audience, defamatory, insulting, violent, racist, xenophobic or revisionist),

that infringes third-party rights (infringing content, violation of personality rights, etc.) and, more generally, that breaches any contractual, legislative or regulatory provision,

that is harmful to third parties in any way whatsoever,

that is false, misleading or offers or promotes unlawful, fraudulent or deceptive activities,

that is harmful to third-party computer systems.

The Customer is responsible for the relationships they may form with other users of the Platform. They undertake to act with discernment and to observe the usual rules of politeness and courtesy in their exchanges with other users.

The Customer indemnifies the Company against any claim and/or action that may be brought against it following a breach of any of the Customer's obligations. The Customer shall compensate the Company for the harm suffered and reimburse it for all sums that it may have to bear as a result.

13. Obligations and liability of the Company

The Company undertakes to provide the Services diligently, it being specified that it is bound by an obligation of means.

The Company undertakes to comply with the regulations in force.

13.1. Quality of the Services

The Company makes its best efforts to provide the Customer with quality Services.

To this end, it regularly carries out checks to verify the operation and accessibility of its Services and may thus carry out maintenance under the conditions specified in the article "Maintenance".

However, the Company is not responsible for temporary difficulties or impossibility of access to its Services that originate from:

circumstances external to its network (and in particular the partial or total failure of the Customer's computer equipment),

the failure of equipment, cabling, services or networks not included in its Services or not under its responsibility,

the interruption of the Services by telecom operators or internet access providers,

the Customer's intervention, in particular through incorrect configuration applied to the Services,

a case of force majeure.

The Company is responsible for the operation of its servers, the outer limits of which are formed by the connection points.

Furthermore, it does not warrant that the Services:

which are the subject of constant research to improve, in particular, their performance and progress, will be entirely free of errors, vices or defects,

being standard and in no way offered according to the Customer's personal constraints, will specifically meet their needs and expectations.

13.2. Service level guarantee of the Solution

The Company offers no service level guarantee for the Solution or the Platform.

However, the Company makes its best efforts to maintain access to the Platform 24 hours a day, 7 days a week, except in the event of planned maintenance under the conditions defined in the article "Maintenance" or force majeure.

13.3. Subcontracting and assignment

The Company may use subcontractors in performing the Services, who are subject to the same obligations as its own when they intervene. It nevertheless remains solely responsible for the proper performance of the Services towards the Customer.

The Company may substitute any person who will be subrogated to all its rights and obligations under its contractual relationship with the Customer. Where applicable, it will inform the Customer of this substitution by any written means.

14. Limitation of the Company's liability

The Company's liability is limited to proven direct damage suffered by the Customer as a result of using the Services.

Except for personal injury, death and gross negligence, and provided that a claim has been made by registered letter with acknowledgement of receipt within one month of the occurrence of the damage, the Company's liability cannot be engaged for an amount greater than the amounts it has received in connection with the provision of its Services.

15. Accepted means of proof

Proof may be established by any means.

The Customer is informed that the messages exchanged through the Platform, as well as the data collected on the Platform and on the Company's computer equipment, constitute one of the accepted means of proof, in particular to demonstrate the reality of the Services performed and the calculation of their price.

16. Terms of processing of personal data

16.1. General provisions

The parties undertake, each for its own part, to comply with all the legal and regulatory obligations incumbent on them in respect of personal data protection, in particular Law no. 78-17 of 6 January 1978, as last amended, known as the French Data Protection Act (Loi Informatique et Libertés), and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (together the "Applicable Regulations").

To find out more about the processing carried out by the Company, the Customer is invited to read the Company's privacy policy available on the Platform.

16.2. Terms of processing of personal data by the Company as a processor

In the course of the Services, the Company is required to process personal data in the name and on behalf of the Customer as a processor, while the Customer acts as controller within the meaning of the Applicable Regulations. The characteristics of the processing are described in Annex 1 of these general terms and conditions.

16.2.1. Data processing

The Company undertakes to process personal data only for the purposes listed in Annex 1 and in accordance with the Customer's documented instructions, including with regard to the transfer of data outside the European Union. The Company undertakes to inform the Customer if, in its opinion, an instruction constitutes a violation of the Applicable Regulations. The Company reserves the right to suspend the processing until the Customer amends the instruction in question so that it no longer violates the Applicable Regulations, without incurring contractual liability as a result of this suspension. This suspension gives rise to no refund of the price of the Services for the period of suspension. If the Customer does not amend but maintains the instruction in question, the Company reserves the right to terminate these terms without notice and without charge.

In addition, if the Company is required to transfer data to a third country or an international organisation under the law applicable to these terms, it must inform the Customer of this legal obligation before the processing, unless the law concerned prohibits such information on important grounds of public interest.

16.2.2. Data security and confidentiality

Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of the processing as well as the risks, of varying likelihood and severity, to the rights and freedoms of natural persons, the Company implements appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including, among others, as required:

a) the pseudonymisation and encryption of personal data;

b) the means to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;

c) the means to restore the availability of 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 the technical and organisational measures for ensuring the security of the processing.

16.2.3. Other processors

The Company is authorised to use the processors (the "Sub-processor(s)") listed in Annex 1 hereto to carry out specific processing activities. In the event of a change to the list of authorised Sub-processors, the Company will inform the Customer in advance and in writing. This information must clearly indicate the subcontracted processing activities and the identity and contact details of the Sub-processor. The Customer has a period of 15 days from the date of receipt of this information to present its legitimate and reasoned objections. If no objection is notified after this period, the Customer will be deemed to have accepted the use of the Sub-processor.

The Sub-processor is bound to comply with the obligations hereof on behalf of and according to the instructions of the Customer. It is for the Company to ensure that the Sub-processor provides the same sufficient guarantees as to the implementation of appropriate technical and organisational measures so that the processing meets the requirements of the Applicable Regulations. If the Sub-processor fails to fulfil its data protection obligations, the Company remains fully liable to the Customer for the performance by the Sub-processor of its obligations.

16.2.4 Transfer of personal data outside the European Union

The Company is authorised to transfer the personal data processed under these general terms and conditions to countries outside the European Union, subject to the implementation of appropriate safeguards as defined in Chapter V of the GDPR.

16.2.5 Assistance and provision of information

The Company undertakes to:

assist the Customer and respond as quickly as possible to any request for information addressed to it by the Customer, whether in the context of an impact assessment or a request from the data protection authorities or the Customer's data protection officer;

as far as possible, assist the Customer in fulfilling its obligation to respond to requests from data subjects exercising their rights under the Applicable Regulations. Where requests are addressed directly to the Company, the Company (i) forwards these requests to the Customer as quickly as possible by e-mail to the address provided by the Customer, and (ii) acknowledges receipt of the requests, informing the data subjects that they have been forwarded to the Customer, who will follow them up as controller;

notify the Customer as quickly as possible after becoming aware of it of any personal data breach concerning the processing covered by these general terms and conditions, and provide it with all useful information and documentation relating to this breach.

16.2.6 Fate of the data

The Company undertakes, at the Customer's choice, to delete the personal data upon expiry of these general terms and conditions or to return it to the Customer and not to keep a copy, unless required by the Applicable Regulations. The Customer has 1 month from the end hereof to make its choice. After this period, the Company will delete all personal data.

16.2.7 Documentation

The Company makes available to the Customer, upon request, all information and documents necessary to demonstrate compliance with its obligations and to allow audits to be carried out. The Customer thus has the possibility of carrying out audits once a year and at its own expense in order to verify the Company's compliance with the obligations provided for in this article. The Customer will inform the Company of the audit with a minimum notice of 2 weeks. The identity of the auditor must be agreed between the Parties. The Company reserves the right in particular to refuse the identity of the chosen auditor if the auditor belongs to a competing company. The audit must be carried out during the Company's working hours and in such a way as to disrupt its activity as little as possible. The audit may thus not undermine in any way (i) the technical and organisational security measures deployed by the Company, (ii) the security and confidentiality of the data of the Company's other customers, and (iii) the proper functioning and organisation of the Company's production. As far as possible, the Parties will agree the scope of the audit in advance. The audit report will be sent to the Company so that it can make any observations or remarks in writing, which will be annexed to the final version of the audit report. Each audit report will be considered confidential information.

16.3. Obligations of the Customer towards the Company

The Customer undertakes to:

provide the Company with the personal data referred to in Annex 2, excluding any irrelevant, disproportionate or unnecessary personal data, and excluding any "special" data within the meaning of the Applicable Regulations, unless the processing justifies it, it being for the Customer to establish such justifications and to take all appropriate measures, in particular prior information, collection of consent and security, for such special data;

collect, under its responsibility, in a lawful, fair and transparent manner, the personal data provided to the Company for the performance of its services, and in particular ensure the legal basis for this collection and the information owed to data subjects;

keep a record of processing activities and, more generally, comply with the principles arising from the Applicable Regulations;

ensure, beforehand and throughout the processing, compliance with the obligations provided for by the Applicable Regulations.

The Customer declares and warrants that it acts as controller and has, before any transmission of data to the Company, the appropriate legal basis (consent, legitimate interest, contractual performance, etc.) allowing the processing of data by the Company.

In this respect, it is the sole responsibility of the Customer: (i) to give data subjects complete and transparent information on the purpose of the processing, in accordance with articles 13 and 14 of the GDPR; (ii) to collect, where applicable, the free, specific, informed and unambiguous consent of data subjects; (iii) to handle data subjects' requests to exercise their rights (access, deletion, objection, etc.).

17. Force majeure

The Company cannot be held liable for failures or delays in the performance of its contractual obligations due to a case of force majeure occurring during its relationship with the Customer, as defined in article 1218 of the French Civil Code.

If the Company is prevented from performing its obligations by a case of force majeure, it must inform the Customer by any written means (and in particular by e-mail). The obligations are suspended upon receipt of the notice, and must be resumed within a reasonable time once the case of force majeure has ceased.

The Company nevertheless remains bound to perform the obligations that are not affected by a case of force majeure.

18. End of the Services

The Subscription must be terminated at the latest:

2 days before the end of the current Period if it is monthly,

1 month before the end of the current Period if it is annual.

The Subscription may be terminated, subject to the notice periods mentioned above, by:

The Customer, directly and free of charge through their Account

The Company, by sending an e-mail to the Customer.

Any Period that has begun is due in full.

Upon expiry or termination of the licence, the Customer loses access to the repository of the paid edition, including the associated packages and updates. The previously installed operating system remains operational on its free base. The Account is kept for the duration of the licence, then deleted after a maximum period of two (2) years of inactivity.

19. Sanctions in the event of breach

The following constitute essential obligations towards the Customer (the "Essential Obligations"):

payment of the price,

not giving the Company false or incomplete information,

not using the Services for a third party,

not engaging in unlawful or fraudulent activities or activities that infringe the rights or security of third parties, undermine public order or breach the laws and regulations in force.

In the event of a breach of any of these Essential Obligations, the Company may:

suspend in whole or in part, or remove, the Customer's access to the Services, including by downgrading the version of the Solution provided to the Customer,

delete any Content related to the breach,

publish on the Platform any informative message that the Company considers useful,

notify any competent authority, cooperate with it and provide it with all information useful for the investigation and prosecution of unlawful or illicit activities,

take any legal action.

These sanctions are without prejudice to any damages that the Company may claim from the Customer.

In the event of a breach of any obligation other than an Essential Obligation, the Company will ask the Customer, by any appropriate written means, to remedy the breach within a maximum of 15 calendar days. The Services will end at the expiry of this period if the breach has not been remedied.

The end of the Services results in the deletion of the Customer's Account.

20. Amendment of the General Terms and Conditions

The Company may amend its General Terms and Conditions at any time and will inform the Customer by any written means (and in particular by e-mail):

at least 5 days before they come into force, if the Subscription is monthly,

at least 45 days before they come into force, if the Subscription is annual.

The amended General Terms and Conditions apply upon renewal of the Customer's Subscription.

If the Customer does not accept these amendments, they must terminate their Subscription as provided in the article "End of the Services".

If the Customer uses the Services after the amended General Terms and Conditions have come into force, the Company considers that the Customer has accepted them.

21. Language

The French language prevails in the event of a contradiction or dispute over the meaning of a term or provision.

22. Applicable law

The General Terms and Conditions are governed by French law.

In the event of a dispute between the Customer and the Company, and failing an amicable agreement within 2 months of the first notification, the dispute will be submitted to the exclusive jurisdiction of the courts of Paris (France), unless mandatory provisions provide otherwise.

Annex 1 - Personal Data

1. Description of the data processing carried out by the Company on behalf of the Customer

Purposes of the processing of personal data	Provision of the Services
Nature of the processing operations	Collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Type of personal data processed	Identification data, contact data
Categories of data subjects	Users (employees, collaborators, etc. of the Customer)
Duration of the processing	Duration of the Services

2. List of authorised Sub-processors

Authorised Sub-processors	Subcontracted processing activities	Location of the processing	Appropriate safeguards put in place in the event of transfer of data outside the EU
Hetzner	Hosting	European Union	N/A
Contabo	Hosting	European Union	N/A
Stripe	Payment service provider	United States	Data Privacy Framework and Standard Contractual Clauses