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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).

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