This Reseller Data Processing Addendum (“DPA”) forms part of the Agreement executed between GoDaddy.com, LLC (inclusive of its affiliated entities if contemplated under the Agreement) (“GoDaddy”) and you (“Reseller”) for the purpose of selling GoDaddy’s product and services (“Services”) through GoDaddy’s Reseller Program, and shall govern with regard to the processing of any Personal Information by Reseller on behalf of GoDaddy. Reseller enters into this DPA on behalf of itself and, to the extent required under applicable Data Protection Laws and Regulations, in the name and on behalf of its authorized affiliates. All capitalized terms not defined herein shall have the meaning set forth in the Agreement. The terms “we”, “us” or “our” shall refer to GoDaddy. The terms “you”, “your”, or “Reseller” shall refer to any individual or entity who accepts this Agreement. Nothing in this Agreement shall be deemed to confer any third-party rights or benefits. This DPA shall become effective and binding as of the date of your electronic acceptance.
This DPA consists of two (2) distinct parts, which are applicable as explained below:
- Data Privacy and Security Standards and Requirements: Application of Data Privacy and Security Standards and Requirements. Applicable to all Resellers that have access to and process PII (as “herein defined”) within the nature and scope of their participation in the Reseller Program.
- Standard Contractual Clauses (and its Appendices 1 & 2): Application of Standard Contractual Clauses. The Standard Contractual Clauses will apply to Customer Data that is transferred outside the EEA, either directly or via onward transfer, to any country not recognized by the European Commission as providing an adequate level of protection for personal data (as described in the GDPR). The Standard Contractual Clauses will not apply to Customer Data that is not transferred, either directly or via onward transfer, outside the EEA. Notwithstanding the foregoing, the Standard Contractual Clauses will not apply where the data is transferred in accordance with a recognized compliance standard for the lawful transfer of personal data (as defined in the GDPR) outside the EEA, such as the EU-US and Swiss-U.S Privacy Shield Frameworks.
Data Privacy and Security SLA
1. Subject Matter and Scope
This Data Privacy and Security SLA (“Security SLA”) is attached and incorporated into the Agreement for the purpose of ensuring any PII (as defined below) collected or utilized by you is handled in a manner that is secure and otherwise in accordance with the terms of the Agreement, this Security SLA, and applicable laws and regulations.
2. Order of Precedence.
This Security SLA is incorporated into and forms part of the Agreement. For matters not addressed under this Security SLA, the terms of the Agreement apply. With respect to the rights and obligation of the parties vis-à-vis each other, in the event of a conflict between the terms of the Agreement and this Security SLA, the terms of this Security SLA will control. In the event of a conflict between the terms of the Security SLA and the Standard Contractual Clauses, the Standard Contractual Clauses will prevail.
3. Personal Information.
- “PII” or “Personal Information,” shall mean information in any medium or form of any kind pertaining to an identified or identifiable natural person or household; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, address, Social Security number or other identification number, e-mail address, telephone number, financial profile, credit card information, driver’s license number, or other information that can be reasonably linked to a particular person, computer, or device (e.g., information collected via tracking technologies, such as IP address), or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person.
- Processing for the purposes of this DPA shall include collecting, recording, organizing, structuring, storing, adapting or altering, retrieving, consulting, using, disclosing, disseminating or otherwise making available, combining, restricting, erasing or destroying PII.
- GoDaddy discloses PII to You solely and exclusively for Your performance of the Services on GoDaddy's behalf and You may only process the PII for the limited and specific purpose(s) described in the Agreement and at our written instructions, and for no other purpose, including with regard to transfers of EU individuals’ PII outside of the European Union, unless required to do so by European Union or European Union Member State law (in which case you must immediately notify us before doing so, unless prohibited from informing us by law).
- You are prohibited from:(i) selling PII; (ii) retaining, using, or disclosing PII for a commercial purpose other than providing the Services; and (iii) retaining, using, or disclosing the PII outside of the Agreement between You and GoDaddy.
- You acknowledge and confirm that PII is not disclosed as consideration for any Services that are provided to GoDaddy under the Agreement. You must not sell any PII, as the term “sell” is defined under California Consumer Privacy Act of 2018, as amended (“CCPA”), and You hereby certify that You understand the rules, requirements and definitions of the CCPA, and all restrictions in this DPA. You agree to refrain from taking any action that would cause any transfers of PII to or from You to qualify as “selling personal information” under the CCPA and any other applicable laws.
- You may only transfer PII relating to EU individuals to outside of the EU (or if such PII is already outside of the EU, to any third party also outside the EU), in compliance with the terms of this DPA and the requirements of Articles 44 to 49 of the GDPR (as defined below).
- You must immediately notify us if, in your opinion, our instruction infringes any applicable data protection laws and regulations, including EU Data Protection Law (as defined below) at firstname.lastname@example.org.
- You must treat all PII as strictly confidential and it must inform all its employees or approved agents engaged in processing the PII of the confidential nature of the PII, and ensure that all such persons or parties have signed an appropriate confidentiality agreement to maintain the confidence of the PII.
- To the extent you receive, maintain, process or otherwise have access to PII in connection with the Reseller Program under the Agreement, you acknowledge and agree that you are responsible for maintaining appropriate organizational and security measures to protect such PII. You must protect and secure such PII in accordance with all applicable privacy and data protection laws, including but not limited to 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 (the “General Data Protection Regulation” or “GDPR”) and associated European Union Member State legislation or regulations (together “EU Data Protection Law”) and CCPA.
- The appropriate organizational and security measures referenced in Section 3.7 shall include as appropriate (but are not limited to):
- Those measures listed below at Sections 3 and 4;
- Measures to ensure that only authorized individuals for the purposes described in the Agreement can access the PII;
- The pseudonymisation and encryption of the PII;
- The ability to ensure continued confidentiality, integrity, availability and resilience of your processing systems and services;
- The ability to restore the availability and access to PII in a timely manner;
- A process for regularly testing, assessing, and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing of PII; and
- Measures to identify vulnerabilities with regard to the processing of PII in your systems.
- To the extent that You contract with any subcontractor, vendor or other third-party to facilitate its performance under the Agreement, You must (i) obtain prior written consent from us; and (ii) enter into a written agreement with such third party to ensure such party also complies with the terms of this DPA and the Agreement.
- Notwithstanding any authorization given by us in accordance with Section 1.11, you will remain fully liable for any such subcontractor, vendor or other third party’s acts where such party fails to fulfill its obligations under this DPA (or similar contractual arrangement put in place to impose equivalent obligations on the third party to those incumbent on you under this DPA) or under applicable privacy law(s).
- You will, at your expense, defend, indemnify and hold us harmless from and against all liability, costs, and loss in connection with any temporary or permanent, accidental or unlawful, unavailability, loss, destruction, unauthorized disclosure of or access to, theft, or compromise of PII, and any other breach of applicable data protection legislation, and any breach of this DPA.
- In the event you becomes aware that you have received our Confidential Information or PII that was not intended for receipt by you or authorized to be received by you under this Agreement, you must (i) promptly notify us at email@example.com, and (ii) unless otherwise instructed in writing, retain the information until you are contacted by firstname.lastname@example.org instructions on what to do with such information.
4. Impact Assessments & Security Audits
- Data Protection Impact Assessments. You must assist us in conducting data protection impact assessments to identify and minimize any privacy or security risks related to the Reseller Program under the Agreement.
- Periodic Audits. We reserve the right to periodically audit (or have a third party, at our direction, audit) your compliance with this DPA.
- Audit after an Incident. In the event of a Reseller security breach, we may conduct a security audit to ensure no PII was impacted. You will be granted 90 days to respond to any issues identified through the audit. Once identified issues have been resolved, we may conduct a security audit to ensure the completion of the resolution.
- Notice of Non-Compliance. Should you become unable to meet any of the commitments in this DPA for any reason, you must notify us immediately. In such case, you must advise whether it is capable of remedying any issue quickly and without jeopardy to the security of any PII. If not, then we may elect to terminate the Agreement without delay, penalty or further liability to you.
5. Security Incident Response
- Notification Timing. You will communicate any security incident related to your services and/or PII to us immediately after discovery thereof and will provide immediate feedback about any impact this incident may/will have on us or PII. You will give its best effort to notify us of the security incident immediately after detecting such incident, but in any event no later than 1 hour after you have detected the incident. An incident for the purposes of this DPA shall also include:
- A complaint or request with respect to the exercise of an individual’s rights under applicable laws including EU Data Protection Law;
- An investigation into or seizure of PII by government officials, regulatory or law enforcement agency, or indications that such investigation or seizure is contemplated;
- Any temporary or permanent, accidental or unlawful, unavailability, loss, destruction, unauthorized disclosure of or access to, theft, or compromise of PII; and
- Any breach of the security and/or confidentiality obligations set out in this DPA.
- Notification Format and Content. Notification of a security breach will take the form of a phone call to our Network Operations Center (NOC) at (480) 505-8809, followed by a written notification to email@example.com. You must provide the following information during the notification phone call, and in the written notice, to the greatest extent possible with further updates as additional information comes to light:
- A description of the nature of the incident and likely consequences of the incident;
- Expected resolution time (if known);
- A description of the measures taken or proposed to address the incident including, measures to mitigate its possible adverse effects on us, PII or associated individuals;
- If the resolution path is unknown at the time of the phone call, you must clarify it is yet undetermined;
- The categories and approximate volume of PII and individuals potentially affected by the incident, and the likely consequences of the incident on that PII and associated individuals; and
- The name and phone number of a Reseller representative we can contact to obtain incident updates.
- Security Resources. We may, upon mutual agreement with you, provide resources from our security group to assist with an identified security breach. You agree to assist us in meeting its obligations in relation to the notification of a security breach under EU Data Protection Law or any other statutory, regulatory, administrative, or contractual breach notification obligations.
- Proprietary Encryption. Secured transactions between you and subcontractor, vendor or other third party, as well as storage of our Confidential Information or PII may not utilize any cryptography algorithms developed internally by you. Any symmetric, asymmetric or hashing algorithm utilized by the application infrastructure will utilize algorithms that have been published and evaluated by the general cryptographic community.
- Encryption Strength. Encryption algorithms must be current industry standard technology and of sufficient strength, such as AES. SHA-256 or RSA public key encryption.
- Hashing Functions. Hashing functions will be a combination of SHA-256 and at least one of MD-5, SHA-2, SHA-3 or similar, not including SHA-1. If alternate hashing functions are to be utilized, they will have explicit approval from our Information Security Team and must be accompanied by at least one approved algorithm.
7. Processing PII
- Compliance with Law. To the extent applicable, you will assist us in our obligations to respond to requests of an individual who’s PII is being processed under the Agreement and who wishes to exercise any of their rights under EU Data Protection Law, including (but not limited to): (i) right of access; (ii) right to data portability; (iii) right to erasure; (iv) right to rectification; (v) right to object to automated decision-making; or (vi) right to object to processing.
- Delete/Destroy. You must securely delete/destroy or return all PII and overwrite physical drives used for its storage using Cryptographic Erase (NIST SP-800-88r1) or equivalent method at any time upon our request or, absent our request, after -termination of the Agreement and destroy or return any existing copies of the same to us.
STANDARD CONTRACTUAL CLAUSES
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
data exporter: GoDaddy.com, LLC and its affiliated entities
data importer: The named Reseller that participated in the Reseller Program subject to the terms of the Agreement.
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.
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 sub-processor’ means any processor engaged by the data importer or by any other sub-processor of the data importer who agrees to receive from the data importer or from any other sub-processor 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, unauthorized disclosure or access, in particular where the processing involves the transmission of data over a network, and against all other unlawful forms of processing.
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 sub-processor 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 sub-processor 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.
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, unauthorized 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 sub-processor 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 sub-processing 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 sub-processing, the processing activity is carried out in accordance with Clause 11 by a sub-processor 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).
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 the Appendix 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 unauthorized access; and
(iii) any request received directly from the data subjects without responding to that request, unless it has been otherwise authorized 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 sub-processing, 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 sub-processing, it has previously informed the data exporter and obtained its prior written consent;
(i) that the processing services by the sub-processor will be carried out in accordance with Clause 11;
(j) to send promptly a copy of any sub-processor agreement it concludes under the Clauses to the data exporter.
(k) that it will, at its expense, defend, indemnify and hold harmless data exporter against all liability and loss in connection with any loss, unauthorized disclosure, theft, or compromise of personal data, and any other breach of applicable data protection legislation by or from data importer.
- 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 sub-processor 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 sub-processor 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 sub-processor 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 sub-processor 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 sub-processor agrees that the data subject may issue a claim against the data sub-processor 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 sub-processor shall be limited to its own processing operations under the Clauses.
Mediation and jurisdiction
- 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.
- 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.
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 sub-processor, 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 sub-processor preventing the conduct of an audit of the data importer, or any sub-processor, pursuant to paragraph 2. In such a case the data exporter shall be entitled to take the measures foreseen in Clause 5(b).
The Clauses shall be governed by the law of the Member State in which the data exporter is established, or where the data exporter is established in multiple jurisdictions, governed by the laws of England and Wales.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
- 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 sub-processor which imposes the same obligations on the sub-processor as are imposed on the data importer under the Clauses. Where the sub-processor fails to fulfill its data protection obligations under such written agreement the data importer shall remain fully liable to the data exporter for the performance of the sub-processor’s obligations under such agreement.
- The prior written contract between the data importer and the sub-processor 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 sub-processor shall be limited to its own processing operations under the Clauses.
- The provisions relating to data protection aspects for sub-processing 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 sub-processing 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.
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 sub-processor 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 sub-processor 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.
to the Standard Contractual Clauses
Additional necessary information if not contained in an accompanying SOW should be included in this Appendix:
The data exporter is the entity identified as GoDaddy, a provider of reseller program for data importer to resell certain products and services of GoDaddy to customers.
The data importer is a reseller of GoDaddy’s product and services.
The data subjects are customers.
Categories of data
The personal data transferred concern the following categories of data:
Customer may submit personal data to the Services which may include, but is not limited to the following categories of personal data:
- First and last name
- Telephone Number
- Physical Address
- Processing operations
The personal data transferred will be subject to the following basic processing activities:
Reseller will process personal data as necessary to perform Services under the Reseller Agreement, and as further instructed by customer throughout its use of the Services.
to the Standard Contractual Clauses
Technical and Organization Security Measures
Data Importer shall maintain technical and administrative safeguards for protection of the security, confidentiality and integrity of customer data, including Personal Data, as set forth in this Data Processing Addendum. Data Importer shall regularly monitor compliance with these safeguards. Data Importer will not materially decrease the overall security of the Services or Reseller Program.