Last Updated: 1 December 2022
We may collect and receive information about users of Our Services (“Users,” “You”, or “Your”) from various sources, including (i) information You provide through Your User account on the Services (Your “Account”) if You register for the Services; (ii) Your use of the Services; and (iii) from third-party websites, services, and partners.
Information We Collect
When You register for an Account, We may ask for Your contact information, including items such as Your name, email address, home address, location, phone number, gender, age, and photo. If You choose to refer a friend to Our Services, We may also collect Your friend’s email address so that We may send them a referral or promotional code to sign up for Our Services.When You register each Keepy™ QR Tag, We may ask for information about the identified object, including:- in case Keepy™ identification tag is attached to a pet: the pet’s name, breed, weight, gender, birth date, spayed/neutered status, size, veterinarian contact, and contact information for the situation the tag is found;- in case Keepy™ identification tag is attached to a person: person’s name, date of birth, address, voluntarily disclosed important care information about blood type, allergies and special conditions, and contact information for the situation the tag is found;- in case Keepy™ identification tag is attached to a thing: Your thing’s name and contact information for the situation the tag is found.II. Payment Information. When You add Your financial account information to Your Account, that information is directed to Our third-party payment processor. We do not store Your financial account information on Our systems; however, We have access to and may retain, subscriber information through Our third-party payment processor.III. Personal Data. This means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a Data Subject in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. “Personal Data” includes equivalent terms in other Data Protection Law, such as the CCPA-defined term “Personal Information,” as context requires.IV. User Content. Our “User Testimonials” feature allows You to publicly post content on Our Services. By providing User Testimonials, You agree that Your profile information and the content You post may be viewed and used by other users and third parties We do not control.VI. Communications. If You contact Us directly, We may receive additional information about You such as Your name, email address, phone number, the contents of the message and/or attachments You may send Us, and any other information You may choose to provide. We may also receive a confirmation when You open an email from us.The personal information that You are asked to provide, and the reasons why You are asked to provide it, will be made clear to You at the point We ask You to provide Your personal information.
Information We Collect When You Use Our Services.
Cookies and Other Tracking Technologies. As is true of most websites, We gather certain information automatically and store it in log files. In addition, when You use Our Services, We may collect certain information automatically from Your device. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, clickstream data, landing page, and referring URL. To collect this information, a cookie may be set on Your computer or device when You visit Our Services. Cookies contain a small amount of information that allows Our web servers to recognize You. We store information that We collect through cookies, log files, and/or clear gifs to record Your preferences. We may also automatically collect information about Your use of features of Our Services, the functionality of Our Services, the frequency of visits, and other information related to Your interactions with the Services. We may track Your use across different websites and services. In some countries, including countries in the European Economic Area (“EEA”), the information referenced above in this paragraph may be considered personal data under applicable data protection laws.II. Usage of Our Services. When You use Our Services, We may collect information about Your engagement with and utilization of Our Services, such as processor and memory usage, storage capacity, navigation of Our Services, and system-level metrics. We use this data to operate the Services, maintain and improve the performance and utilization of the Services, develop new features, protect the security and safety of Our Services and Our customers, and provide customer support. We also use this data to develop aggregate analysis and business intelligence that enable Us to operate, protect, make informed decisions, and report on the performance of Our business.
Information We Collect From Third Parties.
Third-Party Accounts. If You choose to link Our Services to a third-party account, We will receive information about that account, such as Your authentication token from the third-party account, to authorize linking. If You wish to limit the information available to us, You should visit the privacy settings of Your third-party accounts to learn about Your options.
How We Use Information
We use the information We collect in various ways, including to:
- Provide, operate, and maintain Our Services;
- Improve, personalize, and expand Our Services;
- Understand and analyze how You use Our Services;
- Develop new products, services, features, and functionality;
- Communicate with You, either directly or through one of Our partners, including for customer service, to provide You with updates and other information relating to the Service, and for marketing and promotional purposes;
- Process Your transactions;
- Send You text messages and push notifications;
- Find and prevent fraud; and
How We Share Information
We may share the information We collect in various ways, including the following:
- Vendors and Service Providers. We may share information with third-party vendors and service providers that provide services on Our behalf, such as helping to provide Our Services, for promotional and/or marketing purposes, and to provide You with information relevant to You such as product announcements, software updates, special offers, or other information.
- Aggregate Information. Where legally permissible, We may use and share information about users with Our partners in an aggregated and de-identified form that can’t reasonably be used to identify Your identity.
- Advertising. We may work with third-party advertising partners to show You ads that We think may interest You. These advertising partners may set and access their own cookies, pixel tags, and similar technologies on Our Services, and they may otherwise collect or have access to information about You which they may collect over time and across different online services.
- Information We Share When You Sign Up Through a Referral. If You sign up for Our Services through a referral from a friend, We may share information with Your referrer to let them know that You used their referral to sign up for Our Services.
- Business Transfers. Information may be disclosed and otherwise transferred to any potential acquirer, successor, or the assignee as part of any proposed merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of Our business assets.
- With Your Consent. We may share information with Your consent.
Legal Basis for Processing Personal Information
Our legal basis for collecting and using the personal data described above will depend on the personal data concerned and the specific context in which We collect it.However, We will normally collect personal data from You only (i) where We need the personal data to perform a contract with You; (ii) where the processing is in Our legitimate interests and not overridden by Your rights; or (iii) where We have Your consent to do so. We have a legitimate interest in operating Our Services and communicating with You as necessary to provide these Services, for example when responding to Your queries, improving Our platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities.In some cases, We may also have a legal obligation to collect personal data from You or may otherwise need the personal data to protect Your vital interests or those of another person.If We ask You to provide personal data to comply with a legal requirement or to perform a contract with You, We will make this clear at the relevant time and advise You whether the provision of Your personal data is mandatory or not (as well as of the possible consequences if You do not provide Your personal data).
You may access other third-party offerings through the Services, for example by clicking on links to those third-party offerings from within the Services. Keepy™ is not responsible for the privacy policies and/or practices of these third-party offerings, and We encourage You to carefully review their privacy policies.
Keepy™ is committed to protecting Your information. To do so, We employ a variety of security technologies and measures designed to protect information from unauthorized access, use, or disclosure. The measures We use are designed to provide a level of security appropriate to the risk of processing Your personal data. Please note that no service is completely secure. While We strive to protect Your data, We cannot guarantee that unauthorized access, hacking, data loss or a data breach will not occur.DigitalOcean, LLC cloud service provider is our main third-party partner for secure data storage. For more information on DigitalOcean’s security controls, please see the following resources:
We retain personal data We collect from You where We have an ongoing legitimate business need to do so (for example, to provide You with a service You have requested or to comply with applicable legal, tax, or accounting requirements).When We have no ongoing legitimate business need to process Your personal data, We will either delete or anonymize it or, if this is not possible (for example, because Your personal data has been stored in backup archives), then We will securely store Your personal data and isolate it from any further processing until deletion is possible.
You are a registered user, You may access certain information associated with Your Account by logging into Our Services or emailing email@example.com. If You terminate Your Account, any public activity on Your Account prior to deletion may remain stored on Our servers and may remain accessible to the public.To protect Your privacy and security, We may also take reasonable steps to verify Your identity before updating or removing Your information. The information You provide Us may be archived or stored periodically by Us according to backup processes conducted in the ordinary course of business for disaster recovery purposes. Your ability to access and correct Your information may be temporarily limited where access and correction could: inhibit Human Interaction, Inc.'s ability to comply with a legal obligation; inhibit Human Interaction, Inc.'s ability to investigate, make or defend legal claims; result in disclosure of personal data about a third party; or result in a breach of a contract or disclosure of trade secrets or other proprietary business information belonging to Human Interaction, Inc. or a third party.
Your Data Protection Rights Under the General Data Protection Regulation (GDPR)
If You are a resident of the EEA, You have the following data protection rights:
- If You wish to access, correct, update, or request the deletion of Your personal information, You can do so at any time by emailing firstname.lastname@example.org.
- To exercise Your rights to deletion of Your personal data under the GDPR, You can deactivate and purge Your account by using the link “Delete Account” in “Account Settings” in the Main Menu of the Keepy™ Website or Keepy™ Application. All account data will be deleted within 90 days of purging.
- In addition, You can object to the processing of Your personal data, ask Us to restrict the processing of Your personal data, or request portability of Your personal data. Again, You can exercise these rights by emailing email@example.com.
- You have the right to opt out of marketing communications We send You at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails We send You. To opt out of other forms of marketing, please contact Us by emailing firstname.lastname@example.org.
- Similarly, if We have collected and processed Your personal data with Your consent, then You can withdraw Your consent at any time. Withdrawing Your consent will not affect the lawfulness of any processing We conducted prior to Your withdrawal, nor will it affect the processing of Your personal data conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority about Our collection and use of Your personal data. For more information, please contact Your local data protection authority.
We respond to all requests We receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
International Data Transfers
CCPA Privacy Notice
Last Updated on October 19, 2022
We do not sell Your Personal Information.
Use of Personal Information
- Auditing related to a current interaction with You and concurrent transactions, including, but not limited to auditing compliance with this specification and other standards.
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
- Debugging to identify and repair errors that impair existing intended functionality.
- Short-term, transient use.
- Contracting with service providers to perform services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
- Undertaking internal research for technological development and demonstration.
- Undertaking activities to verify or maintain the quality or safety of our services, and to improve, upgrade, or enhance our services.
- Otherwise enabling or effecting, directly or indirectly, a commercial transaction.
- For other purposes for which We provide specific notice at the time the information is collected.
Collection and Disclosure of Personal Information
- Vendors and service providers, including for data analytics and marketing and advertising our products and services to you.
- Third parties integrated into our services.
- Third parties as required by law and similar disclosures.
- Third parties in connection with a merger, sale, or asset transfer.
- Other third parties for whom We have obtained Your permission to disclose Your Personal Information.
Your California Privacy Rights
If You are a California resident, You may exercise the following rights.
Right to Know and Access. You may submit a verifiable request for information regarding the:
(1) categories of Personal Information collected or disclosed by us; (2) purposes for which categories of Personal Information are collected by us; (3) categories of sources from which We collect Personal Information; and (4) specific pieces of Personal Information We have collected about You during the past twelve months.
Right to Delete. Subject to certain exceptions, You have the option to delete Personal Information about You that We have collected from You.
Verification. Requests for access to or deletion of Personal Information are subject to our ability to reasonably verify Your identity in light of the information requested and pursuant to relevant CCPA requirements, limitations, and regulations.
Right to Equal Service and Price. You have the right not to receive discriminatory treatment for the exercise of Your CCPA privacy rights, subject to certain limitations.
Shine the Light. We do not rent, sell, or share Your Personal Information with nonaffiliated companies for their direct marketing purposes unless We have Your permission.
Submit Requests. To exercise Your rights under the CCPA, You can deactivate and purge Your account by using the link “Delete Account” in “Account Settings” in the Main Menu of the Keepy™ Website or Keepy™ Application. For other requests or to authorize an agent to make a request on Your behalf, You can also reach out to Us at email@example.com.
If You have any questions, comments, or concerns about our processing activities, or You would like to exercise Your privacy rights, please email Us at firstname.lastname@example.org.
Standard Contractual Clauses
For the purposes of the Clauses:
Clause 1 Definitions
(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
1. 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.
2. 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.
3. 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.
4. 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 12 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;
Mandatory requirements of the national legislation applicable to the data importer which do not go beyond what is necessary in a democratic society on the basis of one of the interests listed in Article 13(1) of Directive 95/46/EC, that is, if they constitute a necessary measure to safeguard national security, defence, public security, the prevention, investigation, detection and prosecution of criminal offences or of breaches of ethics for the regulated professions, an important economic or financial interest of the State or the protection of the data subject or the rights and freedoms of others, are not in contradiction with the standard contractual clauses. Some examples of such mandatory requirements which do not go beyond what is necessary in a democratic society are, inter alia, internationally recognised sanctions, tax-reporting requirements or anti-money-laundering reporting requirements.
(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
1. 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.
2. 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.
3. 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
1. 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.
2. 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.
3. 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
1. 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.
2. 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.
3. 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.
4. 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
1. 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.
2. 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
The data exporter is the entity defined as the data exporter above.
The data importer is Human Interaction, Inc.
Categories of data
APPENDIX 2 TO THE STANDARD CONTRACTUAL CLAUSES
This Appendix forms part of the Clauses and must be completed by the parties. Description of the technical and organisational security measures implemented by the data importer in accordance with Clauses 4(d) and 5(c) (or document/legislation attached):