DATA PROCESSING ADDENDUM
This Data Processing Addendum (“DPA”) is made between Cognito, LLC., a South Carolina
corporation (“Cognito Forms”) and Taekwondo Academy Tornado (“Customer” or
“Controller” or “Tickets For You Pro”) as an addendum to the Cognito Forms Terms of
Service (the “Terms of Service”) in compliance with the GDPR. This DPA is effective as of
5/31/2018 (“Effective Date”), which is the date Tickets For You Pro indicated its acceptance
of this DPA electronically. This DPA was electronically signed by Vygantas Pundzevicius,
President on behalf of Tickets For You Pro on the Effective Date.
Tickets For You Pro is a Controller of Personal Data collected via their forms and/or
managed by their Account. Cognito Forms is the Processor of this data on behalf of Tickets
For You Pro. Tickets For You Pro will be responsible for Controller obligations in this DPA
and/or ensure that the Controller they work with fulfills these obligations. Specifically,
Tickets For You Pro will ensure that:
ï‚· all applicable posted Privacy Policies permit use of Cognito Forms by Tickets For You
Pro,
ï‚· explicit authorization or consent has been obtained for use of Cognito Forms by
Tickets For You Pro to process this Personal Data, and
ï‚· no additional agreements have been established that would prohibit use of Cognito
Forms by Tickets For You Pro.
Where individual provisions of this DPA are invalid or unenforceable, the validity and
enforceability of the other provisions of this DPA shall not be affected.
Upon the incorporation of this DPA into the Terms of Service, the parties indicated above
are agreeing to the Standard Contractual Clauses (where and as applicable) and all
appendixes attached thereto. In the event of any conflict or inconsistency between this
DPA and the Standard Contractual Clauses in Exhibit 1, the Standard Contractual Clauses
shall prevail.
Cognito Forms and Tickets For You Pro hereby agree to the terms and conditions of this
DPA in compliance with the GDPR.
1. Definitions
“Account” means the business arrangement between a Controller and Cognito Forms that
authorizes the Controller to use Cognito Forms services in accordance with the Terms of
Service. Each Account is represented as an “organization” in Cognito Forms, and this
agreement applies to the organization Tickets For You Pro.
“Controller” means the natural or legal person, public authority, agency, or other body
which, alone or jointly with others, determines the purposes and means of the Processing
of Personal Data.
“Customer” means the Controller who has entered into the Terms of Service with Cognito
Forms.
“Data Subject” means the individual to whom Personal Data relates.
“GDPR” means the General Data Protection 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.
“Personal Data” means any information relating to an identified or identifiable individual
where such information is protected similarly as personal data or personally identifiable
information under applicable Data Protection Law.
“Processing” means any operation or set of operations which is performed on Personal
Data, encompassing the collection, recording, organization, structuring, storage, adaptation
or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or
otherwise making available, alignment or combination, restriction or erasure of Personal
Data.
“Processor” means a natural or legal person, public authority, agency, or other body which
processes Personal Data on behalf of the Controller.
"Services" means the services and other activities to be supplied to or carried out by or on
behalf of Processor for the Controller pursuant to the Terms of Service.
“Standard Contractual Clauses” means the clauses attached hereto as Exhibit 1 pursuant
to the European Commission’s decision (C(2010)593) of 5 February 2010 on Standard
Contractual Clauses for the transfer of personal data to processors established in third
countries which do not ensure an adequate level of data protection.
"Sub-processor" means any person appointed by or on behalf of Processor to Process
Personal Data on behalf of the Controller in connection with the Terms of Service.
“Terms of Service” means the agreement between Cognito Forms and its Customer as set
forth at https://www.cognitoforms.com/terms.
2. Details of Data Processing
2.1 Subject Matter
The subject matter of the data processing under this DPA is the Customer data.
2.2 Duration
As between Cognito Forms and Customer, the duration of the data processing under this
DPA is until the termination of this addendum in accordance with its terms.
2.3 Nature and Purpose
Customer data will be processed in accordance with our privacy policy
(https://www.cognitoforms.com/privacy) for the purpose of providing the services set out
in the Terms of Service (including this DPA) or as otherwise agreed by the parties.
2.4 Types of Personal Data
Determined by Controllers to fulfill the purpose of their use of the Cognito Forms service.
2.5 Categories of Data Subjects
Any individual accessing and/or legally using the Services authorized through the
Customer's Account. Any individual who uses the Services to submit personal data to the
Customer.
3. Obligations and Rights of Controller
Within the scope of this DPA and the Terms of Service, Tickets For You Pro is the Controller
of Personal Data, and Cognito Forms shall process Personal Data only as a data Processor
acting on Controller’s behalf.
The Controller shall comply with its obligations as a Data Controller under GDPR in respect
of its disclosure and transfer of Personal Data to the Processor, the processing of Customer
Data, and any processing instructions it issues. Controller must provide notice and obtain
all consents and rights necessary under GDPR for Processor to process Customer Data and
provide the Services pursuant to the Terms of Service and this DPA.
Controller shall inform Processor comprehensively and without undue delay about any
errors or irregularities related to statutory provisions on the Processing of Personal Data.
4. Obligations and Rights of Processor
Processor shall process Personal Data only for the purposes described in this DPA and only
in accordance with Controller’s documented lawful instructions.
The parties agree that this DPA and the Terms of Service set out the Customer’s complete
and final instructions to Processor in relation to the processing of Personal Data and
processing outside the scope of these instructions (if any) shall require prior written
agreement between Controller and Processor.
If the Processor believes that an instruction of the Controller infringes the GDPR, it shall
immediately inform the Controller without delay. If Processor cannot process Personal
Data in accordance with the instructions due to a legal requirement under any applicable
European Union or Member State law, Processor will (i) promptly notify the Controller of
that legal requirement before the relevant Processing to the extent permitted by the GDPR;
and (ii) cease all Processing (other than merely storing and maintaining the security of the
affected Personal Data) until such time as the Controller issues new instructions with which
Processor is able to comply. If this provision is invoked, Processor will not be liable to the
Controller under the Terms of Service for any failure to perform the applicable services
until the Controller issues new instructions regarding the Processing.
5. Security
5.1 Security Measures
Processor shall implement and maintain appropriate technical and organizational security
measures to protect Personal Data from security incidents and to preserve the security and
confidentiality of the Personal Data, in accordance with the security standards described in
the Terms of Service and this DPA.
5.2 Updates to Security Measures
Controller is responsible for reviewing the information made available by Processor
relating to data security and making an independent determination as to whether the
Services meet Controller’s requirements and legal obligations under the GDPR. Controller
acknowledges that the security measures are subject to technical progress and
development and that Processor may update or modify the security measures from time to
time provided that such updates and modifications do not result in the degradation of the
overall security of the Services purchased by the Controller.
5.3 Controller Responsibilities
Notwithstanding the above, Controller agrees that except as provided by this DPA,
Controller is responsible for its secure use of the Services, including securing its Account
authentication credentials, protecting the security of Personal Data when in transit to and
from the Services, and taking any appropriate steps to securely encrypt or backup any
Personal Data uploaded to the Services.
6. Confidentiality
Processor shall ensure that any personnel authorized to process Customer Data on its
behalf, including employees, affiliates and sub-processors, is subject to confidentiality
obligations, whether contractual or statutory, with respect to that Customer Data.
7. Personal Data Breach
In the event of a security breach that may affect Personal Data, Processor will notify
Controller of the breach upon becoming aware of the breach without undue delay.
Processor will provide a description of the nature of the breach and affected data. If the
breach compromises Personal Data collected by Controller, the Controller is obligated to
promptly notify all affected parties.
8. Data Subject Rights
Processor will provide reasonable assistance, including by appropriate technical and
organizational measures and taking into account the nature of the Processing, to enable
Controller to respond to any request from Data Subjects seeking to exercise their rights
under the GDPR with respect to Personal Data (including access, rectification, restriction,
deletion or portability of Personal Data, as applicable), to the extent permitted by the law.
If such request is made directly to Processor, Processor will promptly inform Controller and
will advise Data Subjects to submit their request to the Controller. Controller shall be solely
responsible for responding to any Data Subjects’ requests. Controller shall reimburse
Processor for the costs arising from this assistance.
9. Sub-processors
9.1 Authorized Sub-processors
Controller agrees that Processor may engage Sub-processors to process Personal Data on
Controller's behalf. Sub-processors currently engaged by Cognito Forms and authorized by
Tickets For You Pro are identified in the Cognito Forms Privacy Policy.
Processor shall enter into a written agreement with any Sub-processor imposing data
protection terms that require the Sub-processor to protect the Personal Data to the
standard required by the GDPR and remain responsible for its compliance with the
obligations of this DPA and for any acts or omissions of the Sub-processor that cause
Processor to breach any of its obligations under this DPA.
9.2 Changes to Sub-processors
Processor shall maintain and make available in the Cognito Forms Privacy Policy an up-todate
list of the Sub-processors it has appointed, and will notify Controller (for which email
shall suffice) if it adds or removes Sub-processors at least 10 days prior to any such
changes. If the Controller objects to the changes in Sub-processors, the Controller' sole
remedy will be to terminate their Account, thus terminating this DPA and the Terms of
Service agreement and ending further Processing of Personal Data on their behalf.
10. Data Transfers
To the extent that Cognito Forms processes any Personal Data protected by the GDPR in a
country that has not been designated by the European Commission or Swiss Federal Data
Protection Authority (as applicable) as providing an adequate level of protection for
Personal Data, the parties acknowledge that Cognito Forms shall be deemed to provide
adequate protection (within the meaning of EU Data Protection Law) for any such Personal
Data by virtue of having self-certified its compliance with Privacy Shield. Processor agrees
to protect such Personal Data in accordance with the requirements of the Privacy Shield
Principles.
11. Deletion or Retrieval of Personal Data
Processor shall, at the choice of the Controller, delete or return all Personal Data to the
Controller after the end of the provision of services relating to processing. Controller must
inform and instruct Processor on return of data in advance of terminating the agreement,
as well a bear any additional cost arising with the return or deletion of Personal Data.
If Controller terminates the Terms of Service, by deleting the organization Tickets For You
Pro, without prior written notification to Processor, Processor will permanently delete all
Personal Data in its possession.
12. Audits
Controller may, upon reasonable and timely advance agreement, during regular business
hours and without interrupting Processor’s business operations, conduct an on-site
inspection of Processor’s business operations to demonstrate Processor’s compliance with
this Addendum in relation to the Processing of the Company Personal Data, or have the
same conducted by a qualified third party which shall not be a competitor of Processor.
Processor shall, upon Controller’s written request and within a reasonable period of time,
provide Controller with all information necessary for such audit, to the extent that such
information is within Processor’s control and Processor is not precluded from disclosing it
by applicable law, a duty of confidentiality, or any other obligation owed to a third party
and provided that Controller not exercise this right more than once per year.
Controller may also review the SOC 2 Report or another audit of Provider's systems by an
independent third party ("Third Party Audit"), if such a report is available.
Processor shall immediately inform Controller if, in its opinion, an instruction infringes this
Regulation or other Union or Member State data protection provisions.
Agreement Date: 5/31/2018
Taekwondo Academy Tornado
By:
Vygantas Pundzevicius
President
Cognito, LLC
By:
Jamie Thomas
Co-founder
Exhibit 1 - Standard Contractual Clauses (Processors)
For the purposes of Article 26(2) of Directive 95/46/EC for the transfer of personal data to
processors established in third countries which do not ensure an adequate level of data
protection,
The Controller, as defined in the Cognito Forms Terms of Service (the “data exporter”)
And
Cognito Forms, 929 Gervais Street Suite D, Columbia, SC 29201 (the “data importer”),
each a ‘party’; together ‘the parties’,
HAVE AGREED on the following Contractual Clauses (the Clauses) in order to adduce
adequate safeguards with respect to the protection of privacy and fundamental rights and
freedoms of individuals for the transfer by the data exporter to the data importer of the
personal data specified in Appendix 1.
Clause 1 - Definitions
For the purposes of the Clauses:
(a) ‘personal data’, ‘special categories of data’, ‘process/processing’, ‘controller’, ‘processor’,
‘data subject’ and ‘supervisory authority’ shall have the same meaning as in Directive
95/46/EC of the European Parliament and of the Council of 24 October 1995 on the
protection of individuals with regard to the processing of personal data and on the free
movement of such data;
(b) ‘the data exporter’ means the controller who transfers the personal data;
(c) ‘the data importer’ means the processor who agrees to receive from the data exporter
personal data intended for processing on his behalf after the transfer in accordance with
his instructions and the terms of the Clauses and who is not subject to a third country’s
system ensuring adequate protection within the meaning of Article 25(1) of Directive
95/46/EC;
(d) ‘the subprocessor’ means any processor engaged by the data importer or by any other
subprocessor of the data importer who agrees to receive from the data importer or from
any other subprocessor of the data importer personal data exclusively intended for
processing activities to be carried out on behalf of the data exporter after the transfer in
accordance with his instructions, the terms of the Clauses and the terms of the written
subcontract;
(e) ‘the applicable data protection law’ means the legislation protecting the fundamental
rights and freedoms of individuals and, in particular, their right to privacy with respect to
the processing of personal data applicable to a data controller in the Member State in
which the data exporter is established;
(f) ‘technical and organisational security measures’ means those measures aimed at
protecting personal data against accidental or unlawful destruction or accidental loss,
alteration, unauthorised disclosure or access, in particular where the processing involves
the transmission of data over a network, and against all other unlawful forms of
processing.
Clause 2 - Details of the transfer
The details of the transfer and in particular the special categories of personal data where
applicable are specified in Appendix 1 which forms an integral part of the Clauses.
Clause 3 - Third-party beneficiary clause
The data subject can enforce against the data exporter this Clause, Clause 4(b) to (i), Clause
5(a) to (e), and (g) to (j), Clause 6(1) and (2), Clause 7, Clause 8(2), and Clauses 9 to 12 as
third-party beneficiary.
The data subject can enforce against the data importer this Clause, Clause 5(a) to (e) and
(g), Clause 6, Clause 7, Clause 8(2), and Clauses 9 to 12, in cases where the data exporter
has factually disappeared or has ceased to exist in law unless any successor entity has
assumed the entire legal obligations of the data exporter by contract or by operation of
law, as a result of which it takes on the rights and obligations of the data exporter, in which
case the data subject can enforce them against such entity.
The data subject can enforce against the subprocessor this Clause, Clause 5(a) to (e) and
(g), Clause 6, Clause 7, Clause 8(2), and Clauses 9 to 12, in cases where both the data
exporter and the data importer have factually disappeared or ceased to exist in law or have
become insolvent, unless any successor entity has assumed the entire legal obligations of
the data exporter by contract or by operation of law as a result of which it takes on the
rights and obligations of the data exporter, in which case the data subject can enforce
them against such entity. Such third-party liability of the subprocessor shall be limited to its
own processing operations under the Clauses.
The parties do not object to a data subject being represented by an association or other
body if the data subject so expressly wishes and if permitted by national law.
Clause 4 - Obligations of the data exporter
The data exporter agrees and warrants:
(a) that the processing, including the transfer itself, of the personal data has been and will
continue to be carried out in accordance with the relevant provisions of the applicable data
protection law (and, where applicable, has been notified to the relevant authorities of the
Member State where the data exporter is established) and does not violate the relevant
provisions of that State;
(b) that it has instructed and throughout the duration of the personal data-processing
services will instruct the data importer to process the personal data transferred only on the
data exporter’s behalf and in accordance with the applicable data protection law and the
Clauses;
(c) that the data importer will provide sufficient guarantees in respect of the technical and
organisational security measures specified in Appendix 2 to this contract;
(d) that after assessment of the requirements of the applicable data protection law, the
security measures are appropriate to protect personal data against accidental or unlawful
destruction or accidental loss, alteration, unauthorised disclosure or access, in particular
where the processing involves the transmission of data over a network, and against all
other unlawful forms of processing, and that these measures ensure a level of security
appropriate to the risks presented by the processing and the nature of the data to be
protected having regard to the state of the art and the cost of their implementation;
(e) that it will ensure compliance with the security measures;
(f) that, if the transfer involves special categories of data, the data subject has been
informed or will be informed before, or as soon as possible after, the transfer that its data
could be transmitted to a third country not providing adequate protection within the
meaning of Directive 95/46/EC;
(g) to forward any notification received from the data importer or any subprocessor
pursuant to Clause 5(b) and Clause 8(3) to the data protection supervisory authority if the
data exporter decides to continue the transfer or to lift the suspension;
(h) to make available to the data subjects upon request a copy of the Clauses, with the
exception of Appendix 2, and a summary description of the security measures, as well as a
copy of any contract for subprocessing services which has to be made in accordance with
the Clauses, unless the Clauses or the contract contain commercial information, in which
case it may remove such commercial information;
(i) that, in the event of subprocessing, the processing activity is carried out in accordance
with Clause 11 by a subprocessor providing at least the same level of protection for the
personal data and the rights of data subject as the data importer under the Clauses; and
(j) that it will ensure compliance with Clause 4(a) to (i).
Clause 5 - Obligations of the data importer
The data importer agrees and warrants:
(a) to process the personal data only on behalf of the data exporter and in compliance with
its instructions and the Clauses; if it cannot provide such compliance for whatever reasons,
it agrees to inform promptly the data exporter of its inability to comply, in which case the
data exporter is entitled to suspend the transfer of data and/or terminate the contract;
(b) that it has no reason to believe that the legislation applicable to it prevents it from
fulfilling the instructions received from the data exporter and its obligations under the
contract and that in the event of a change in this legislation which is likely to have a
substantial adverse effect on the warranties and obligations provided by the Clauses, it will
promptly notify the change to the data exporter as soon as it is aware, in which case the
data exporter is entitled to suspend the transfer of data and/or terminate the contract;
(c) that it has implemented the technical and organisational security measures specified in
Appendix 2 before processing the personal data transferred;
(d) that it will promptly notify the data exporter about:
(i) any legally binding request for disclosure of the personal data by a law
enforcement authority unless otherwise prohibited, such as a prohibition under
criminal law to preserve the confidentiality of a law enforcement investigation;
(ii) any accidental or unauthorised access; and
(iii) any request received directly from the data subjects without responding to that
request, unless it has been otherwise authorised to do so;
(e) to deal promptly and properly with all inquiries from the data exporter relating to its
processing of the personal data subject to the transfer and to abide by the advice of the
supervisory authority with regard to the processing of the data transferred;
(f) at the request of the data exporter to submit its data-processing facilities for audit of the
processing activities covered by the Clauses which shall be carried out by the data exporter
or an inspection body composed of independent members and in possession of the
required professional qualifications bound by a duty of confidentiality, selected by the data
exporter, where applicable, in agreement with the supervisory authority;
(g) to make available to the data subject upon request a copy of the Clauses, or any existing
contract for subprocessing, unless the Clauses or contract contain commercial information,
in which case it may remove such commercial information, with the exception of Appendix
2 which shall be replaced by a summary description of the security measures in those
cases where the data subject is unable to obtain a copy from the data exporter;
(h) that, in the event of subprocessing, it has previously informed the data exporter and
obtained its prior written consent;
(i) that the processing services by the subprocessor will be carried out in accordance
with Clause 11;
(j) to send promptly a copy of any subprocessor agreement it concludes under the
Clauses to the data exporter.
Clause 6 - Liability
The parties agree that any data subject, who has suffered damage as a result of any breach
of the obligations referred to in Clause 3 or in Clause 11 by any party or subprocessor is
entitled to receive compensation from the data exporter for the damage suffered.
If a data subject is not able to bring a claim for compensation in accordance with paragraph
1 against the data exporter, arising out of a breach by the data importer or his
subprocessor of any of their obligations referred to in Clause 3 or in Clause 11, because the
data exporter has factually disappeared or ceased to exist in law or has become insolvent,
the data importer agrees that the data subject may issue a claim against the data importer
as if it were the data exporter, unless any successor entity has assumed the entire legal
obligations of the data exporter by contract of by operation of law, in which case the data
subject can enforce its rights against such entity.
The data importer may not rely on a breach by a subprocessor of its obligations in order to
avoid its own liabilities.
If a data subject is not able to bring a claim against the data exporter or the data importer
referred to in paragraphs 1 and 2, arising out of a breach by the subprocessor of any of
their obligations referred to in Clause 3 or in Clause 11 because both the data exporter and
the data importer have factually disappeared or ceased to exist in law or have become
insolvent, the subprocessor agrees that the data subject may issue a claim against the data
subprocessor with regard to its own processing operations under the Clauses as if it were
the data exporter or the data importer, unless any successor entity has assumed the entire
legal obligations of the data exporter or data importer by contract or by operation of law,
in which case the data subject can enforce its rights against such entity. The liability of the
subprocessor shall be limited to its own processing operations under the Clauses.
Clause 7 - Mediation and jurisdiction
1. The data importer agrees that if the data subject invokes against it third-party
beneficiary rights and/or claims compensation for damages under the Clauses, the data
importer will accept the decision of the data subject:
(a) to refer the dispute to mediation, by an independent person or, where
applicable, by the supervisory authority;
(b) to refer the dispute to the courts in the Member State in which the data exporter
is established.
2. The parties agree that the choice made by the data subject will not prejudice its
substantive or procedural rights to seek remedies in accordance with other provisions of
national or international law.
Clause 8 - Cooperation with supervisory authorities
The data exporter agrees to deposit a copy of this contract with the supervisory authority if
it so requests or if such deposit is required under the applicable data protection law.
The parties agree that the supervisory authority has the right to conduct an audit of the
data importer, and of any subprocessor, which has the same scope and is subject to the
same conditions as would apply to an audit of the data exporter under the applicable data
protection law.
The data importer shall promptly inform the data exporter about the existence of
legislation applicable to it or any subprocessor preventing the conduct of an audit of the
data importer, or any subprocessor, pursuant to paragraph 2. In such a case the data
exporter shall be entitled to take the measures foreseen in Clause 5(b).
Clause 9 - Governing law
The Clauses shall be governed by the law of the Member State in which the data exporter is
established.
Clause 10 - Variation of the contract
The parties undertake not to vary or modify the Clauses. This does not preclude the parties
from adding clauses on business related issues where required as long as they do not
contradict the Clause.
Clause 11 - Subprocessing
The data importer shall not subcontract any of its processing operations performed on
behalf of the data exporter under the Clauses without the prior written consent of the data
exporter. Where the data importer subcontracts its obligations under the Clauses, with the
consent of the data exporter, it shall do so only by way of a written agreement with the
subprocessor which imposes the same obligations on the subprocessor as are imposed on
the data importer under the Clauses. Where the subprocessor fails to fulfil its data
protection obligations under such written agreement the data importer shall remain fully
liable to the data exporter for the performance of the subprocessor’s obligations under
such agreement.
The prior written contract between the data importer and the subprocessor shall also
provide for a third-party beneficiary clause as laid down in Clause 3 for cases where the
data subject is not able to bring the claim for compensation referred to in paragraph 1 of
Clause 6 against the data exporter or the data importer because they have factually
disappeared or have ceased to exist in law or have become insolvent and no successor
entity has assumed the entire legal obligations of the data exporter or data importer by
contract or by operation of law. Such third-party liability of the subprocessor shall be
limited to its own processing operations under the Clauses.
The provisions relating to data protection aspects for subprocessing of the contract
referred to in paragraph 1 shall be governed by the law of the Member State in which the
data exporter is established.
The data exporter shall keep a list of subprocessing agreements concluded under the
Clauses and notified by the data importer pursuant to Clause 5(j), which shall be updated at
least once a year. The list shall be available to the data exporter’s data protection
supervisory authority.
Clause 12 - Obligation after the termination of personal data-processing
services
The parties agree that on the termination of the provision of data-processing services, the
data importer and the subprocessor shall, at the choice of the data exporter, return all the
personal data transferred and the copies thereof to the data exporter or shall destroy all
the personal data and certify to the data exporter that it has done so, unless legislation
imposed upon the data importer prevents it from returning or destroying all or part of the
personal data transferred. In that case, the data importer warrants that it will guarantee
the confidentiality of the personal data transferred and will not actively process the
personal data transferred anymore.
The data importer and the subprocessor warrant that upon request of the data exporter
and/or of the supervisory authority, it will submit its data-processing facilities for an audit
of the measures referred to in paragraph 1.
APPENDIX 1 - to the Standard Contractual Clauses
This Appendix forms part of the Clauses. The Member States may complete or specify,
according to their national procedures, any additional necessary information to be
contained in this Appendix.
A. Data exporter
The data exporter is the Customer, as defined in the Cognito Forms Terms of
Service.
B. Data importer
The data importer is Cognito, LLC, a South Carolina based limited liability
corporation that provides web-based form building tools and services.
C. Data subjects
Categories of data subjects set out in Section 2 of the Data Processing Agreement to
which the Clauses are attached.
D. Categories of data
Categories of personal data set out under Section 2 of the Data Processing
Agreement to which the Clauses are attached.
E. Special categories of data (if appropriate)
The parties do not anticipate the transfer of special categories of data.
F. Processing operations
The processing activities set out under Section 2 of the Data Processing Agreement
to which the Clauses are attached.
APPENDIX 2 - Security Measures
The Security Measures applicable to the Services are described here:
https://www.cognitoforms.com/features/security (as updated from time to time in
accordance with Section 5.2 of this DPA).