(a) “Affiliate” means any entity that directly or indirectly controls, is controlled by, or is under common control with the subject entity. “Control”, for purposes of this definition, means direct or indirect ownership or control of more than 50% of the voting interests of the subject entity.
(b) “CCPA/CPRA” means the California Consumer Privacy Act of 2018, Cal. Civ. Code §§ 1798.100 et. seq, and its implementing regulations, as may be amended from time to time, including the California Privacy Rights Act.
(c) The terms, “Controller”, “Member State“, “Processor“, “Processing” and “Supervisory Authority” shall have the same meaning as in the GDPR. The terms “Business”, “Business Purpose”, “Consumer” and “Service Provider” shall have the same meaning as in the CCPA/CPRA.
(d) For the purpose of clarity, within this DPA “Controller” shall also mean “Business”, and “Processor” shall also mean “Service Provider”, to the extent that the CCPA/CRPA applies. In the same manner, Processor’s Sub-processor shall also refer to the concept of Service Provider.
(e) “Data Protection Laws” means all applicable and binding privacy and data protection laws and regulations, including such laws and regulations of the European Union, the European Economic Area and their Member States, Switzerland, the United Kingdom, Canada, and the United States of America, as applicable to the Processing of Personal Data under the Agreement including (without limitation) the GDPR, the UK GDPR, the FADP, the CCPA/CPRA, and other U.S. state comprehensive consumer privacy laws, as known or reasonably expected by AllVoices to be applicable to the Processing of Personal Data hereunder and in effect at the time of Processor’s performance hereunder.
(f) “Data Subject” means the identified or identifiable person to whom the Personal Data relates.
(g) “GDPR” means the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).
(h) “Personal Data” or “Personal Information” means any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, to or with an identified or identifiable natural person, including Subscriber’s account holders and authorized users of the Services, to the extent such information is processed by AllVoices solely on behalf of Subscriber, under this DPA and the Agreement between Subscriber and AllVoices.
(i) “Security Measures” means the security measures applicable to the Services licensed by Subscriber, as updated from time to time, and as set forth herein.
(j) “Sensitive Data” means Personal Data that is protected under a special legislation and requires unique treatment, such as “special categories of data”, “sensitive data” or other materially similar terms under applicable Data Protection Laws.
(k) “Standard Contractual Clauses” shall mean (i) the standard contractual clauses set out in the Annex of Commission Implementing Decision (EU) 2021/914 of 4 June 2021 (“EU SCCs”); or (ii) where the UK GDPR applies, the International Data Transfer Addendum to the EU SCCs issued by the Information Commissioner’s Office in the UK, as applicable.
(l) “Sub-processor” means any third party that Processes Personal Data under the instruction or supervision of AllVoices, and is set forth in greater detail herein in Schedule D.
(m) “UK GDPR” means the Data Protection Act 2018, as well as the GDPR as it forms part of the law of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018 and as amended by the Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019 (SI 2019/419).
2.1 Roles of the Parties. The Parties acknowledge and agree that with regard to the Processing of Personal Data performed solely on behalf of Subscriber, (i) Subscriber is the Controller of Personal Data, (ii) AllVoices is the Processor of such Personal Data, (iii) for the purposes of the CCPA/CPRA (and to the extent applicable), Subscriber is the “Business” and AllVoices is the “Service Provider” (as such terms are defined in the CCPA/CPRA), with respect to Processing of Personal Data described in this Section 2.1. The terms “Controller” and “Processor” below hereby signify Subscriber and AllVoices, respectively.
2.2 Subscriber Processing of Personal Data. Subscriber, in its use of the Service, and Subscriber’s instructions to the Processor, shall comply with Data Protection Laws. Subscriber shall establish and have any and all required legal bases in order to collect, Process and transfer to Processor the Personal Data, and to authorize the Processing by Processor, and for Processor’s Processing activities on Subscriber’s behalf, including the pursuit of ‘business purposes’ as defined under the CCPA/CPRA.
2.3 Processor’s Processing of Personal Data. When Processing on Subscriber’s behalf under the Agreement, Processor shall Process Personal Data for the following purposes: (i) Processing in accordance with the Agreement and this DPA; (ii) Processing for Subscriber as part of its provision of the Services; (iii) Processing to comply with Subscriber’s reasonable and documented instructions, where such instructions are consistent with the terms of the Agreement, regarding the manner in which the Processing shall be performed; (iv) Processing as required under the laws applicable to Processor, and/or as required by a court of competent jurisdiction or other competent governmental or semi-governmental authority, provided that Processor shall inform Subscriber of the legal requirement before Processing, unless such law or order prohibit such information on important grounds of public interest.
Processor shall inform Subscriber without undue delay if, in Processor’s opinion, an instruction for the Processing of Personal Data given by Subscriber infringes applicable Data Protection Laws. To the extent that Processor cannot comply with an instruction from Subscriber, Processor (i) shall inform Subscriber, providing relevant details of the issue, (ii) Processor may, without liability to Subscriber, temporarily cease all Processing of the affected Personal Data (other than securely storing such data) and/or suspend Subscriber’s access to the Services, and (iii) if the Parties do not agree on a resolution to the issue in question and the costs thereof, Subscriber may, as its sole remedy, terminate the Agreement and this DPA with respect to the affected Processing, and Subscriber shall pay to Processor all the amounts owed to Processor or due before the date of termination. Subscriber will have no further claims against Processor (including, without limitation, requesting refunds for Service) pursuant to the termination of the Agreement and the DPA as described in this paragraph.
2.4 Details of the Processing. The subject-matter of Processing of Personal Data by Processor is the performance of the Service pursuant to the Agreement. The duration of the Processing, the nature and purpose of the Processing, the types of Personal Data and categories of Data Subjects Processed under this DPA are further specified in Schedule A (Details of Processing) to this DPA.
2.5 Sensitive Data. The Services include both features that are not designed to receive Sensitive Data and features that are designed to Process it. Where Subscriber enables or uses any feature of the Services intended for the intake or management of accommodation requests, leave of absence requests, or related interactive-process records (the “Accommodations Features”), Subscriber’s enablement and use of those features constitutes Subscriber’s documented instruction to Processor to Process Sensitive Data, including health and medical information, for the purposes described in Schedule A. The Parties further acknowledge that workplace reports, feedback, messages and investigation records submitted through any feature of the Services may contain Sensitive Data volunteered by a Data Subject on an unsolicited basis. Subscriber shall establish and maintain a lawful basis for the Processing of Sensitive Data, including, where the GDPR applies, a condition under Article 9(2) of the GDPR and any applicable Member State law adopted under Article 9(2)(b) or Article 9(4), and shall provide all notices and obtain all consents required under Data Protection Laws. Processor shall apply to Sensitive Data the safeguards described in Section 3 of this DPA and in Annex I.B of Schedule B, including logical segregation of records created through the Accommodations Features from other case records and role-based access controls limiting access to those of Subscriber’s authorized users whom Subscriber designates. Subscriber shall not submit, and shall use reasonable efforts not to permit its authorized users to submit, Sensitive Data through modules or free-text fields of the Services not designed to receive it, and Processor shall have no liability arising from Sensitive Data submitted by a Data Subject on an unsolicited basis or by Subscriber in contravention of this Section 2.5.
2.6 CCPA/CPRA Standard of Care; No Sale of Personal Information. Processor acknowledges and confirms that it does not receive or process any Personal Information as consideration for any services or other items that Processor provides to Subscriber under the Agreement. Processor shall not have, derive, or exercise any rights or benefits regarding Personal Information Processed on Subscriber’s behalf, nor shall it combine the Personal Information Processed on Subscriber’s behalf with any information it processes on behalf of any other parties, by way of logical separation, and may use and disclose Personal Information solely for the purposes for which such Personal Information was provided to it, as stipulated in the Agreement and this DPA. Processor certifies that it understands the rules, requirements and definitions of the CCPA/CPRA and agrees to refrain from selling and/or sharing (as such term is defined in the CCPA/CPRA) any Personal Information Processed hereunder, nor taking any action that would cause any transfer of Personal Information to or from Processor under the Agreement or this DPA to qualify as “selling” or “sharing” such Personal Information under the CCPA/CPRA.
2.7 Artificial Intelligence; No Model Training. Processor shall not use, and shall not permit any Sub-processor to use, Personal Data Processed on Subscriber’s behalf to train, fine-tune, or otherwise develop or improve any generative artificial intelligence or machine learning model, other than a model used solely to provide the Services to Subscriber and from which Subscriber’s Personal Data is not made available to any third party or to any other customer of Processor. Processor’s agreement with each Sub-processor providing artificial intelligence services requires that such Sub-processor not retain Subscriber’s Personal Data other than as necessary to return an output to Processor, and not use such Personal Data for model training or development.
2.8 Anonymous and Pseudonymous Reports. Where the Services permit a Data Subject to submit a report on an anonymous or pseudonymous basis, Processor shall not attempt to identify or re-identify that Data Subject, and shall not permit any Sub-processor to do so, except to the extent compelled by applicable law or expressly requested by the Data Subject.
2.9 Employment Records; No Protected Health Information. Personal Data Processed under the Agreement, including health and medical information Processed through the Accommodations Features, consists of employment records maintained by Subscriber in its capacity as an employer and does not constitute protected health information within the meaning of the Health Insurance Portability and Accountability Act of 1996 and its implementing regulations (“HIPAA”). Subscriber shall not submit to the Services protected health information received by Subscriber in its capacity as a plan sponsor, or received from a group health plan, a business associate, or a health care clearinghouse. Processor is not a business associate of Subscriber for purposes of HIPAA, and no business associate agreement is required in connection with the Services. Should Subscriber require Processor to Process protected health information, the Parties must first execute a separate business associate agreement, and Processor has no obligation to enter into such an agreement.
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 to the rights and freedoms of natural persons, Processor will implement technical and organizational measures to ensure a level of security appropriate to that risk. In assessing the appropriate level of security, Processor shall, in particular, take into account the risks that are presented by the Processing, in particular from unauthorized or unlawful Processing, accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data transmitted, stored or otherwise Processed. Processor shall provide reasonable assistance to Subscriber in ensuring Subscriber meets its own compliance obligations with respect to these same security measures. Processor shall ensure that its personnel authorized to Process Personal Data are bound by written obligations of confidentiality (or are under an appropriate statutory obligation of confidentiality), receive appropriate data protection and information security training, and are granted access to Personal Data only on a need-to-know basis in accordance with Processor’s role-based access controls. Taking into account the nature of the Processing and the information available to Processor, Processor shall further provide reasonable assistance to Subscriber with respect to Subscriber’s obligations under Articles 32 to 36 of the GDPR (and equivalent provisions of other Data Protection Laws), including data protection impact assessments and prior consultation with a Supervisory Authority. Details of Processor's technical and organizational measures are as set forth in the Processor's Trust Center located at https://trust.allvoices.co/ , which is incorporated herein by reference (“Trust Center”). Processor shall not materially reduce the security measures described therein during the Term of this Agreement without providing Subscriber reasonable prior written notice.
AllVoices maintains a current SOC 2 Type II attestation report and ISO/IEC 27001 certification with respect to the systems used to Process Personal Data, designed to ensure a level of security appropriate to the risk.
Processor maintains security incident management policies and procedures and, to the extent required under applicable Data Protection Laws, shall notify Subscriber without undue delay after becoming aware of the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data Processed by Processor on behalf of the Subscriber (a “Data Incident”). Processor’s notification shall, to the extent then known and as further information becomes available, describe the nature of the Data Incident, the categories and approximate number of Data Subjects and records concerned, the likely consequences of the Data Incident, and the measures taken or proposed to be taken to address it, and Processor shall provide such further reasonable cooperation and information as Subscriber requires in order to meet its own notification obligations under Data Protection Laws. Processor shall make reasonable efforts to identify and take those steps as Processor deems necessary and reasonable in order to remediate and/or mitigate the cause of such Data Incident to the extent the remediation and/or mitigation is within Processor’s reasonable control. The obligations herein shall not apply to incidents that are caused by Subscriber or Subscriber’s authorized users. Subscriber will not make, disclose, release or publish any finding, admission of liability, communication, notice, press release or report concerning any Data Incident which directly or indirectly identifies Processor (including in any legal proceeding or in any notification to regulatory or supervisory authorities or affected individuals) without Processor’s prior written approval, unless, and solely to the extent that, Subscriber is compelled to do so pursuant to applicable Data Protection Laws. In the latter case, unless prohibited by such laws, Subscriber shall provide Processor with reasonable prior written notice to provide Processor with the opportunity to object to such disclosure and in any case, Subscriber will limit the disclosure to the minimum scope required.
5.1 Appointment of Sub-processors. Subscriber acknowledges and agrees that Processor may engage third-party Sub-processors in connection with the provision of the Service.
5.2 List of Current Sub-processors and Notification of New Sub-processors. Processor makes available to Subscriber the current list of Sub-Processors used by Processor to process Personal Data on Schedule D. Such Sub-processor list includes the identities of those Sub-processors and the entity’s country (“Sub-Processor List”). The Sub-Processor List as of the date of first use of the Service by Subscriber is hereby deemed authorized upon first use of the Services.
5.3 Processor’s webpage accessible at https://www.allvoices.co/legal/subprocessors offers a mechanism to subscribe to notifications of new Sub-processors used to Process Personal Data, to which Subscriber may also subscribe, and when Subscriber subscribes to such mechanism, Processor shall provide notification of any new Sub-processor(s) not less than seven (7) days before authorizing such new Sub-processor(s) to Process Personal Data in connection with the provision of the Services. Processor shall also post each new Sub-processor to the webpage at https://trust.allvoices.co/subprocessors not less than seven (7) days prior to authorizing such Sub-processor to Process Personal Data, and such posting shall constitute notice to Subscriber for purposes of this Section 5 and Clause 9 of the EU SCCs. For clarity, if Subscriber does not subscribe to the foregoing mechanism of notice, Subscriber waives any rights to object to any new Sub-processor
5.4 Objection to New Sub-processors. Subscriber may reasonably object to Processor’s use of a new Sub-processor, for reasons relating to the protection of Personal Data intended to be Processed by such Sub-processor, by notifying Processor promptly in writing within seven (7) days after receipt of a Processor notification in accordance with the mechanism set out in Section 5.3. Such written objection shall include the reasons for objecting to Processor’s use of such new Sub-processor. Failure to object to such new Sub-processor in writing within seven (7) days following Processor’s notice shall be deemed as acceptance of the new Sub-Processor. In the event Subscriber reasonably objects to a new Sub-processor, as permitted in the preceding sentences, Processor will use reasonable efforts to make available to Subscriber a change in the Service or recommend a commercially reasonable change to Subscriber’s configuration or use of the Service to avoid Processing of Personal Data by the objected-to new Sub-processor without unreasonably burdening the Subscriber. If Processor is unable to make available such change within thirty (30) days, Subscriber may, as a sole remedy, terminate the applicable Agreement and this DPA with respect only to those Service which cannot be provided by Processor without the use of the objected-to new Sub-processor, by providing written notice to Processor. All amounts due under the Agreement before the termination date with respect to the Processing at issue shall be duly paid to Processor. Until a decision is made regarding the new Sub-processor, Processor may temporarily suspend the Processing of the affected Personal Data and/or suspend access to the Services. Subscriber will have no further claims against Processor due to the termination of the Agreement (including, without limitation, requesting refunds) and/or the DPA in the situation described in this paragraph.
5.5 Agreements with Sub-processors. Processor has entered into a written agreement with each Sub-processor containing appropriate safeguards to the protection of Personal Data. Where Processor engages a Sub-processor for carrying out specific Processing activities on behalf of the Subscriber, the same or materially similar data protection obligations as set out in this DPA shall be imposed on such new Sub-processor by way of a contract, in particular obligations to implement appropriate technical and organizational measures in such a manner that the processing will meet the requirements of the applicable Data Protection Law. Where a Sub-processor fails to fulfil its data protection obligations concerning its processing of Personal Data, Processor shall remain responsible for the performance of the Sub-processor’s obligations.
The rights of data subjects shall be asserted against Controller. Processor will, to the extent legally permitted, provide reasonable assistance to Subscriber to respond to requests from Data Subjects to exercise their rights under Applicable Data Protection Law (e.g., rights to access or delete Personal Information) in a manner that is consistent with the nature and functionality of the Services. In the event that AllVoices receives any such request, it shall notify the Subscriber without undue delay and, unless legally required to do so or otherwise instructed by Subscriber, shall not itself respond to the request. Subscriber is responsible for handling such requests by a Data Subject in accordance with Applicable Data Protection Law.
7.1 As applicable, Controller may supervise Processor’s compliance with this DPA and relevant Data Protection Laws by being provided suitable current certificates, reports or statements of evidence from independent bodies of compliance with the technical and organizational measures.
7.2 Demonstrating Compliance with this DPA.
7.2.1 Subject to Section 7.2.2, Processor shall make available to Subscriber information necessary to demonstrate compliance with its obligations under this DPA and allow for (and contribute to) audits, including inspections conducted by Subscriber or another auditor under the instruction of the Subscriber for the same purposes of demonstrating compliance with the obligations set out in this DPA.
7.2.2 Subscriber’s rights under Section 7.2.1 of the DPA are subject to the following:
If requested by Subscriber, on no more often than an annual basis during the term of the Agreement, AllVoices shall provide Subscriber with a copy of the result of its annual SOC 2, Type II audit within a reasonable period after receiving the report from its auditor. Any audit or inspection permitted under Section 7.2.1 shall: (i) be conducted no more than once in any twelve (12) month period, except where required by a Supervisory Authority or following a Data Incident affecting Subscriber’s Personal Data; (ii) be preceded by not less than thirty (30) days’ prior written notice; (iii) be conducted during regular business hours, in accordance with Processor’s on-site policies, and in a manner that does not unreasonably disrupt Processor’s business or compromise the security or confidentiality of any other customer’s data; (iv) be conducted by Subscriber or by an independent third-party auditor that is not a competitor of Processor and that has executed a confidentiality agreement reasonably acceptable to Processor; and (v) be at Subscriber’s sole cost and expense.
To the extent that Processor can demonstrate compliance with its obligations set out in this DPA by adhering to an approved code of conduct, by obtaining an approved certification or by providing Subscriber with an audit report issued by an independent third party auditor (provided that Subscriber will comply with appropriate confidentiality obligations as set out in the Agreement and shall not use such audit report for any other purpose), such code of conduct, certification or audit report shall be the presumptive means of demonstrating such compliance, and Subscriber shall not conduct an audit or inspection under Section 7.2.1 unless (i) the information so provided is not sufficient to demonstrate Processor’s compliance with this DPA, or (ii) Subscriber is required to conduct an audit or inspection by a Supervisory Authority.
8.1 As applicable, the Parties agree that the EU SCC will apply to EU Personal Data transferred from Controller, either directly from the EU or via onward transfer, to Processor as Processor is located in the United States. The Parties agree to delete the optional provision in Clause 11 and choose Option 1 in Clause 17, and to select Option 2 (general written authorisation) in Clause 9 with the seven (7) day notice period set out in Section 5.3 of this DPA. The Parties agree that the blank lines in Clauses 17 and 18 shall state Ireland. The Annexes to the EU SCC are attached to this DPA as Schedule B. In the event of any conflict or inconsistency between the provisions of this DPA and the EU SCC, the provisions of the EU SCC shall prevail. In the event that any provision of the EU SCC is held illegal or unenforceable in a judicial proceeding, such provision shall be severed and shall be inoperative, and the remainder of the SCC and the terms of this DPA shall remain operative and binding on the Parties.
8.2 As applicable, The Parties agree that the UK Addendum (as set out in Schedule C) will apply to UK Personal Data transferred from Controller, either directly from the UK or via onward transfer, to Processor as Processor is located in the United States. The UK Addendum is incorporated into this DPA as Schedule C. In the event of any conflict or inconsistency between the provisions of this DPA and the UK Addendum, the provisions of the UK Addendum shall prevail. In the event that any provision of the UK Addendum is held illegal or unenforceable in a judicial proceeding, such provision shall be severed and shall be inoperative, and the remainder of the UK Addendum and the terms of this DPA shall remain operative and binding on the Parties.
8.3 For data transfers of Personal Data other than EU Personal Data and UK Personal Data, each Party shall abide by all Applicable Laws of the territory of origin of the Personal Data.
The duration and termination of this DPA shall be tied to the duration and termination of the Agreement. Following termination of the Agreement, Processor shall, at Controller's election made by written notice to Processor within thirty (30) days of such termination, either (i) delete all Personal Information Processed on Controller’s behalf under the Agreement, including Personal Information submitted directly to the Services by Data Subjects, or (ii) return such Personal Information to Controller in a commercially reasonable format and thereafter delete it, in either case within ninety (90) days of such election (or, if no election is made within such thirty (30) day period, Processor shall proceed to delete such Personal Information within ninety (90) days following the end of that period). Upon Controller's written request, Processor shall provide written confirmation that such deletion has occurred. Notwithstanding the foregoing, Processor may retain Personal Information, and documentation evidencing the orderly Processing thereof, to the extent required by Applicable Law.
This Section 10 applies only applies to Personal Information subject to protection under the CCPA/CPRA (“California Personal Information”). To the extent a term is capitalized but not defined in this Section 10, the applicable definition from the CCPA/CPRA applies.
10.1 Role of the Parties. For purposes of the CCPA/CPRA, the parties hereby agree that Controller is a Business and Processor a Service Provider when Service Provider is processing California Personal Information pursuant to Business instructions.
10.2 Data Processing; Transfer; Sale. Service Provider shall Process California Personal Information as a Service Provider solely as necessary to perform services pursuant to the Agreement (“Business Purpose”) or as otherwise permitted by the CCPA/CPRA. Service Provider shall not (i) Sell or Share California Personal Information; (ii) process California Personal Information outside the business relationship between the parties, unless required by applicable law; or (iii) combine California Personal Information provided by Controller with personal data from another source (excluding information received from another source when acting as Service Provider pursuant to the Agreement). The parties acknowledge and agree that the disclosure of California Personal Information by the Business to Service Provider does not constitute consideration between the parties.
10.3 Compliance. Service Provider shall comply with its CCPA/CPRA obligations, including but not limited to the protection of California Personal Information as required by the CCPA/CPRA. If Service Provider determines it is no longer able to comply with its CCPA/CPRA obligations, Service Provider shall promptly provide notice thereof.
10.4 Notice. The Business shall notify end users that their California Personal Information is being used or shared consistent with Cal. Civ. Code 1798.130.
10.5 Business’s Right to Monitor and Remediate. Business may take reasonable and appropriate steps to ensure that Service Provider’s Processing of California Personal Information is consistent with Business’s obligations under the CCPA, and, upon written notice to Service Provider, to stop and remediate any unauthorized use of California Personal Information. Any audit or inspection undertaken in connection with the foregoing rights shall be conducted in accordance with, and subject to the limitations of, Section 7.2.2 of this DPA. The limitations of Section 7.2.2 shall not apply to Business’s right, upon written notice, to stop and remediate unauthorized use of California Personal Information.
In the event of a conflict between this Section 10 and another section of this DPA as it relates to the CCPA/CPRA, Section 10 controls.
This DPA and any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with it or its subject matter or formation shall be governed by and construed in accordance with the laws of the State of California and the applicable federal laws of the United States, without regard to its conflict of laws principles, and subject in all cases to Clause 17 of the EU SCCs and Section 8 of this DPA with respect to any Restricted Transfer. The terms of this DPA shall apply only to the extent required by Applicable Data Protection Law. To the extent not inconsistent herewith, the applicable provisions of the Agreement(s) (including without limitation, indemnifications, limitations of liability, enforcement, and interpretation) shall apply to this DPA. In the event of any conflict between this DPA and the terms of an applicable Agreement, the terms of this DPA shall control solely with respect to data processing terms where required by Applicable Data Protection Law, and, in all other respects, the terms of the applicable Agreement shall control. If any provision of this DPA is found by a court of competent jurisdiction to be unenforceable or invalid, that provision will be changed and interpreted to accomplish the objectives of such provision to the greatest extent possible under applicable law and the remaining provisions will remain in full force and effect. Any amendments, supplements or the cancellation of this DPA must be in writing (email sufficient).
Last Updated:
September 9, 2026
