This Data Processing Agreement (“DPA”) forms part of the Sherloq Agreement (the “Agreement”) between the customer (the “Customer” or “Data Controller”) and Sherloq (“Sherloq”, “we”, “us”, “our”, or “Data Processor”) and applies to the extent Sherloq processes Personal Data on behalf of the Customer in the course of providing services.
WHEREAS, Sherloq provides services to the Customer as described in the Agreement (the “Services”);
WHEREAS, in providing the Services, Sherloq may process Personal Data on behalf of the Customer in the capacity of a Data Processor, and the parties wish to define their respective responsibilities regarding such processing, in accordance with applicable data protection laws;
NOW THEREFORE, by accessing or using the Services, the Customer agrees to the terms of this DPA, and both parties undertake to comply with the following provisions with respect to the processing of Personal Data, each acting reasonably and in good faith.
1. INTERPRETATION AND DEFINITIONS
1.1 The headings contained in this DPA are for convenience only and shall not be interpreted to limit or otherwise affect the provisions of this DPA. References to clauses or sections are references to the clauses or sections of this DPA unless otherwise stated. Words used in the singular include the plural and vice versa, as the context may require. Capitalized terms not defined herein shall have the meanings assigned to such terms in the Agreement. Definitions:
(a) “Affiliate” means any entity that directly or indirectly controls, is controlled by, or is under common control with the subject entity. “Control”, for purposes of this definition, means direct or indirect ownership or control of more than 50% of the voting interests of the subject entity.
(b) “Authorized Affiliate” means any of Customer’s Affiliate(s) which (a) is subject to the Data Protection Laws And Regulations of the European Union, the European Economic Area and/or their member states, Switzerland and/or the United Kingdom, and (b) is permitted to use the Services pursuant to the Agreement between Customer and Sherloq, but has not signed its own agreement with Sherloq and is not a “Customer” as defined under the Agreement.
(c) “Controller” or “Data Controller” means the entity which determines the purposes and means of the Processing of Personal Data. For the purposes of this DPA only, and except where indicated otherwise, the term “Data Controller” shall include the Organization and/or the Organization’s Authorized Affiliates.
(d) "CCPA" means the California Consumer Privacy Act of 2018 and its modifications and amendments
(e) “DataProtectionLawsandRegulations” means all laws and regulations of the European Union, the European Economic Area and their Member States, the United Kingdom, and the Israeli Privacy Protection Law, 1981 and the regulations promulgated thereunder (including Privacy Protection Regulations (Transfer of Data to Databases Abroad), 5761-2001 and Privacy Protection Regulations (Data Security), 5777-2017), and any binding instructions, guidelines and requirements of the Israeli Privacy Protection Authority, as applicable to the Processing of Personal Data under the Agreement.
(f) “DataSubject” means the identified or identifiable person to whom the Personal Data relates.
(g) “MemberState” means a country that belongs to the European Union and/or the European Economic Area. “Union” means the European Union.
(h) “GDPR” means the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).
(i) “PersonalData” or “Personal Information” means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, 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, as defined under Data Protection Laws and Regulations and/or under the CCPA, as applicable. For the avoidance of doubt, Customer's business contact information is not by itself deemed to be Personal Data subject to this DPA.
(j) “Process(ing)” means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
(k) “Processor” or “Data Processor” means the entity which Processes Personal Data on behalf of the Controller.
(l) “SecurityDocumentation” means the Security Documentation applicable to the specific Services purchased by Customer, as updated from time to time. Customer shall send a request to noy@sherloqdata.io to receive a copy of the Security Documentation.
(m) “Sherloq” means the relevant Sherloq entity of the following Sherloq legal entities as specified in this DPA and/or in the Agreement, including: Sherloqdata Ltd.
(n) “SherloqGroup” means Sherloq and its Affiliates engaged in the Processing of Personal Data.
(o) “Standard Contractual Clauses” or “SCCs” means (i) the standard contractual clauses for the transfer of Personal Data to Data processors established in third countries which do not ensure an adequate level of protection as set out in Regulation (EU) 2016/679 of the European Parliament and of the Council from June 4, 2021, as available here, as updated, amended, replaced or superseded from time to time by the European Commission; or (ii) where required from time to time by a supervisory authority for use with respect to any specific restricted transfer, any other set of contractual clauses or other similar mechanism approved by such Supervisory Authority or by Applicable Laws for use in respect of such Restricted Transfer, as updated, amended, replaced or superseded from time to time by such Regulatory Authority or Data Protection Laws and Regulations;
(p) “Sub-processor” means any Processor engaged by Sherloq and/or Sherloq Affiliate to Process Personal Data on behalf of Customer.
(q) “SupervisoryAuthority” means an independent public authority which is established by an EU Member State pursuant to the GDPR.
2. PROCESSING OF PERSONAL DATA
2.1 The Parties acknowledge and agree that with regard to the Processing of Personal Data under this DPA, the Customer is the Controller of the Personal Data and Sherloq is the processor of such data, except when the Customer acts as a Processor of the Personal Data, in which case Sherloq is a sub-processor. For clarity, this DPA shall not apply with respect to Sherloq processing activity as a Data Controller with respect to Sherloq data as detailed in Sherloq’s privacy policy.
2.2 Customer shall, in its use of the Services, Process Personal Data in accordance with the requirements of Data Protection Laws and Regulations and comply at all times with the obligations applicable to data controllers. For the avoidance of doubt, Customer’s instructions for the Processing of Personal Data shall comply with Data Protection Laws and Regulations. Customer shall have sole responsibility for the means by which Customer acquired Personal Data. Without limitation, Customer shall comply with any and all transparency-related obligations (including, without limitation, displaying any and all relevant and required privacy notices or policies) and shall at all times have any and all required ongoing legal bases in order to collect, Process and transfer to Sherloq the Personal Data and to authorize the Processing by Sherloq of the Personal Data which is authorized in this DPA. Customer shall defend, hold harmless and indemnify Sherloq, its Affiliates and subsidiaries (including without limitation their directors, officers, agents, subcontractors and/or employees) from and against any liability of any kind related to any breach, violation or infringement by Customer and/or its authorized users of any Data Protection Laws and Regulations and/or this DPA and/or this Section.
2.3 Sherloq’s Processing of Personal Data.
2.3.1 Subject to the Agreement, Sherloq shall Process Personal Data that is subject to this DPA only in accordance with Customer’s documented instructions as necessary for the performance of the Services and for the performance of the Agreement and this DPA, unless required to otherwise by Union or Member State law or any other applicable law to which Sherloq and its Affiliates are subject, in which case, Sherloq shall inform the Customer of the legal requirement before processing, unless that law prohibits such information on important grounds of public interest. The duration of the Processing, the nature, and purposes of the Processing, as well as the types of Personal Data Processed and categories of Data Subjects under this DPA are further specified in Schedule 1 (Details of the Processing) to this DPA.
2.3.2 To the extent that Sherloq or its Affiliates cannot comply with a request (including, without limitation, any instruction, direction, code of conduct, certification, or change of any kind) from Customer and/or its authorized users relating to Processing of Personal Data or where Sherloq considers such a request to be unlawful, Sherloq (i) shall inform Customer, providing relevant details of the problem (but not legal advice), (ii) Sherloq may, without any kind of liability towards Customer, temporarily cease all Processing of the affected Personal Data (other than securely storing those data), and (iii) if the Parties do not agree on a resolution to the issue in question and the costs thereof, each Party may, as its sole remedy, terminate the Agreement and this DPA with respect to the affected Processing, and Customer shall pay to Sherloq all the amounts owed to Sherloq or due before the date of termination. Customer will have no further claims against Sherloq (including, without limitation, requesting refunds for Services) due to the termination of the Agreement and/or the DPA in the situation described in this paragraph (excluding the obligations relating to the termination of this DPA set forth below).
2.3.3 Sherloq will not be liable in the event of any claim brought by a third party, including, without limitation, a Data Subject, arising from any act or omission of Sherloq, to the extent that such is a result of Customer’s instructions.
3. RIGHTS OF DATA SUBJECTS. If Sherloq receives a request from a Data Subject to exercise its rights as laid down in Chapter III of the GDPR (“Data Subject Request”), Sherloq shall, to the extent legally permitted, promptly notify, and forward such Data Subject Request to Customer. Taking into account the nature of the Processing, Sherloq shall use commercially reasonable efforts to assist Customer by appropriate technical and organizational measures, insofar as this is possible, for the fulfilment of Customer’s obligation to respond to a Data Subject Request under Data Protection Laws and Regulations. To the extent legally permitted, Customer shall be responsible for any costs arising from Sherloq’s provision of such assistance.
4. SHERLOQ PERSONNEL
4.1 Sherloq shall grant access to the Personal Data to persons under its authority (including, without limitation, its personnel) only on a need to know basis and ensure that such persons engaged in the Processing of Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality.
4.2 Sherloq may disclose and Process the Personal Data (a) as permitted hereunder (b) to the extent required by a court of competent jurisdiction or other Supervisory Authority and/or otherwise as required by applicable laws or applicable Data Protection Laws and Regulations (in such a case, Sherloq shall inform the Customer of the legal requirement before the disclosure, unless that law prohibits such information on important grounds of public interest), or (c) on a “need-to-know” basis under an obligation of confidentiality to legal counsel(s), data protection advisor(s), accountant(s), investors or potential acquirers.
5. AUTHORIZATION REGARDING SUB-PROCESSORS
5.1 Sherloq’s current list of Sub-processors is included in Schedule 2 (“Sub-processor List”) and is hereby approved by Data Controller. Customer hereby grants a general authorization to Sherloq to appoint new Sub-processors, and Sherloq shall comply with the conditions of Section 5.2, to 5.4.
5.2 Customer may reasonably object to Sherloq’s use of a Sub-processor for reasons related to the Data Protection Laws and Regulations by notifying Sherloq promptly in writing within three (3) business days after receipt of Sherloq’s notice in accordance with the mechanism set out in Section 5.2 and such written objection shall include the reasons related to the Data Protection Laws and Regulations for objecting to Sherloq’s use of such Sub-processor. Failure to object to such Sub-processor in writing within three (3) business days following Sherloq’s notice shall be deemed as acceptance of the Sub-Processor. In the event Customer reasonably objects to a Sub-processor, as permitted in the preceding sentences, Sherloq will use reasonable efforts to make available to Customer a change in the Services or recommend a commercially reasonable change to Customer’s use of the Services to avoid Processing of Personal Data by the objected-to Sub-processor without unreasonably burdening the Customer. If Sherloq is unable to make available such change within a reasonable period of time, which shall not exceed thirty (30) days, Customer may, as a sole remedy, terminate the applicable Agreement and this DPA with respect only to those Services which cannot be provided by Sherloq without the use of the objected-to Sub-processor by providing written notice to Sherloq provided that all amounts due under the Agreement before the termination date with respect to the Processing at issue shall be duly paid to Sherloq. Until a decision is made regarding the Sub-processor, Sherloq may temporarily suspend the Processing of the affected Personal Data. Customer will have no further claims against Sherloq due to the termination of the Agreement (including, without limitation, requesting refunds) and/or the DPA in the situation described in this paragraph.
5.3 This Section 5 shall not apply to subcontractors of Sherloq which provide ancillary services to support the performance of the DPA. This includes, for example, telecommunication services, maintenance and user service, cleaning staff, or auditors.
6. SECURITY AND AUDITS.
Taking into account the state of the art, Sherloq shall maintain all industry-standard technical and organizational measures required pursuant to Article 32 of the GDPR. Upon Customer’s written request at reasonable intervals (subject to the confidentiality obligations), Sherloq shall make available to Customer relevant information that is necessary to demonstrate compliance with the obligations laid down in this Section (provided, however, that such information shall only be used by Customer to assess compliance with this Section, and shall not be disclosed to any third party without Sherloq’s prior written approval). At Customer’s cost and expense, Sherloq shall allow audits conducted by the Customer or another auditor mandated by Customer, provided that the Parties shall agree on the scope, methodology and timing of such audits and inspections. Notwithstanding anything to the contrary, such audits and/or inspections shall not contain any information, including without limitation, Personal Data that does not belong to Customer.
7. PERSONAL DATA INCIDENT MANAGEMENT AND NOTIFICATION. Sherloq shall notify Customer without undue delay after becoming aware of the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data, including Personal Data, transmitted, stored, or otherwise Processed by Sherloq of which Sherloq becomes aware (a “Personal Data Incident”). Sherloq shall make reasonable efforts to identify the cause of such Personal Data Incident and take those steps as Sherloq deems necessary, possible, and reasonable in order to remediate the cause of such a Personal Data Incident to the extent the remediation is within Sherloq’s reasonable control. In any event, Customer will be the party responsible for notifying supervisory authorities and/or concerned data subjects (where required by Data Protection Laws and Regulations).
8. RETURN AND DELETION OF PERSONAL DATA. Subject to the Agreement, Sherloq shall, at the choice of Customer, delete or return the Personal Data to Customer after the end of the provision of the Services relating to Processing, and shall delete existing copies unless applicable law requires storage of the Personal Data. In any event, to the extent required or allowed by applicable law, Sherloq may retain one copy of the Personal Data for evidence purposes and/or for the establishment, exercise, or defence of legal claims and/or to comply with applicable laws and regulations. If the Customer requests the Personal Data to be returned, the Personal Data shall be returned in the format generally available for Sherloq’s Customers.
9. AUTHORIZED AFFILIATES
9.1 The Parties acknowledge and agree that, by executing the DPA, the Customer enters into the DPA on behalf of itself and, as applicable, in the name and on behalf of its Authorized Affiliates, thereby establishing a separate DPA between Sherloq. Each Authorized Affiliate agrees to be bound by the obligations under this DPA. All access to and use of the Services by Authorized Affiliates must comply with the terms and conditions of the Agreement and this DPA and any violation of the terms and conditions therein by an Authorized Affiliate shall be deemed a violation by Customer.
9.2 The Customer shall remain responsible for coordinating all communication with Sherloq under the Agreement and this DPA and shall be entitled to make and receive any communication in relation to this DPA on behalf of its Authorized Affiliates.
10. TRANSFERS OF DATA
10.1 Personal Data may be transferred from the EU Member States, the three EEA member countries (Norway, Liechtenstein and Iceland) (collectively, “EEA”), the United Kingdom to countries that offer adequate level of data protection under or pursuant to the adequacy decisions published by the relevant data protection authorities of the EEA, the Union, the Member States or the European Commission, the UK supervisory authority (“Adequacy Decisions”), without any further safeguard being necessary.
10.2 To the extent that there is Processing of Personal Data which includes transfers from the EEA, the UK to countries which do not offer adequate level of data protection or which have not been subject to an Adequacy Decision (“Other Countries”), the below terms shall apply:
Customer as a Data Exporter (as defined in the SCCs) and Sherloq on behalf of itself and each Sherloq Affiliate (as applicable) as a Data Importer (as defined in the SCCs) hereby enter into the SCC set out in Schedule 3. To the extent that there is any conflict or inconsistency between the terms of the SCC and the terms of this DPA, the terms of the SCC shall take precedence.
11. TERMINATION. This DPA shall automatically terminate upon the termination or expiration of the Agreement under which the Services are provided. Sections 2.2, 2.3.3, 8 and 13 shall survive the termination or expiration of this DPA for any reason. This DPA cannot, in principle, be terminated separately to the Agreement, except where the Processing ends before the termination of the Agreement, in which case, this DPA shall automatically terminate.
12. CCPA. To the extent that the Personal Data is subject to the CCPA, Sherloq shall not sell or share Customer's Personal Data. Sherloq acknowledges that when processing Personal Data in the context of the provision of the Services, Customer is not selling or sharing Personal Data to Sherloq. Sherloq agrees not to retain, use or disclose Customer Personal Data: (i) for any purpose other than the Business Purpose (as defined below); (ii) for no other commercial or Business Purpose; or (iii) outside the direct business relationship between Sherloq and Customer. Notwithstanding the foregoing, Sherloq may use, disclose, or retain Customer Personal Data to: (i) transfer the Personal Data to other Sherloq entities (including, without limitation, affiliates and subsidiaries), service providers, third parties and vendors, in order to provide the Services to Customer; (ii) to comply with, or as allowed by, applicable laws; (iii) to defend legal claims or comply with a law enforcement investigation; (ii) for internal use by Sherloq to build or improve the quality of its services and/or for any other purpose permitted under the CCPA; (iii) to detect data security incidents, or protect against fraudulent or illegal activity; and (iv) collect and analyse anonymous information. Sherloq shall use commercially reasonable efforts to comply with its obligations under CCPA. If Sherloq becomes aware of any material applicable requirement (to Sherloq as a service provider) under CCPA that Sherloq cannot comply with, Sherloq shall use commercially reasonable efforts to notify Customer. Upon written Customer’s notice, Sherloq shall use commercial reasonable and appropriate steps to stop and remediate Sherloq's alleged unauthorized use of Personal Data; provided that Customer must explain and demonstrate in the written notice which processing activity of Personal Data it considers to be unauthorized and the applicable reasons. Sherloq shall use commercially reasonable efforts to enable Customer to comply with consumer requests made pursuant CCPA. Notwithstanding anything to the contrary, Customer shall be fully and solely responsible for complying with its own requirements under CCPA. “Business purpose” means the Processing activities that Sherloq will perform to provide Services (as described in the Agreement), this DPA and any other instruction from Customer, as otherwise permitted by applicable law, including, CCPA and the applicable regulations, or as otherwise necessary to provide the Services to Customer.
13. RELATIONSHIP WITH AGREEMENT. In the event of any conflict between the provisions of this DPA and the provisions of the Agreement, the provisions of this DPA shall prevail over the conflicting provisions of the Agreement. Notwithstanding anything to the contrary in the Agreement and/or in any agreement between the parties and to the maximum extent permitted by law: (A) Sherloq’s (including Sherloq’s Affiliates’) entire, total and aggregate liability, related to personal data or information, privacy, or for breach of, this DPA and/or Data Protection Laws and Regulations, including, without limitation, if any, any indemnification obligation or applicable law regarding data protection or privacy, shall be limited to the amounts paid to Sherloq under the Agreement within twelve (12) months preceding the event that gave rise to the claim. This limitation of liability is cumulative and not per incident; (B) In no event will Sherloq and/or Sherloq Affiliates and/or their third-party providers, be liable under, or otherwise in connection with this DPA for: (i) any indirect, exemplary, special, consequential, incidental or punitive damages; (ii) any loss of profits, business, or anticipated savings; (iii) any loss of, or damage to data, reputation, revenue or goodwill; and/or (iv) the cost of procuring any substitute goods or services; and (C) The foregoing exclusions and limitations on liability set forth in this Section shall apply: (i) even if Sherloq, Sherloq Affiliates or third-party providers, have been advised, or should have been aware, of the possibility of losses or damages; (ii) even if any remedy in this DPA fails of its essential purpose; and (iii) regardless of the form, theory or basis of liability (such as, but not limited to, breach of contract or tort).
14. AMENDMENTS. This DPA may be amended at any time by a written instrument duly signed by each of the Parties.
15. LEGAL EFFECT. Sherloq may assign this DPA or its rights or obligations hereunder to any Affiliate thereof, or to a successor or any Affiliate thereof, in connection with a merger, consolidation or acquisition of all or substantially all of its shares, assets or business relating to this DPA or the Agreement. Any Sherloq obligation hereunder may be performed (in whole or in part), and any Sherloq right (including invoice and payment rights) or remedy may be exercised (in whole or in part), by an Affiliate of Sherloq.
List of Schedules
● SCHEDULE 1 - DETAILS OF THE PROCESSING
● SCHEDULE 2 - SUB-PROCESSOR LIST
● SCHEDULE 3 – STANDARD CONTRACTUAL CLAUSES
SCHEDULE 1 - DETAILS OF THE PROCESSING
Subject matter. Sherloq will Process Personal Data as necessary to perform the Services pursuant to the Agreement, as further instructed by Customer in its use of the Services.
Nature and Purpose of Processing.
1. Performing the Agreement, this DPA and/or other contracts executed by the Parties, including, providing the Service(s) to Customer, including providing the AI Functionalities, and providing support and technical maintenance, if agreed in the Agreement
2. For Sherloq to comply with documented reasonable instructions provided by Customer where such instructions are consistent with the terms of the Agreement.
Duration of Processing. Subject to any Section of the DPA and/or the Agreement dealing with the duration of the Processing and the consequences of the expiration or termination thereof, Sherloq will Process Personal Data for the duration of the Agreement, unless otherwise agreed upon in writing.
Type of Personal Data. Customer may submit Personal Data to the Services, the extent of which is determined and controlled by Customer in its sole discretion, and which may include, but is not limited to the following categories of Personal Data:
● Full Name
● Email address
● IP address
● Personal Data that users will share while using Sherloq's tool.
● Information shared with our AI Chat and AI Functionalities
● Any other Personal Data or information that the Customer decides to provide to the Sherloq or the Services.
The Customer and the Data Subjects shall provide the Personal data to Sherloq by supplying the Personal data to Sherloq’s Service.
For the avoidance of doubt, the information subject to the Sherloq’s privacy policy (e.g., log-in details) available here: https://www.sherloqdata.io/privacy-policy/ shall not be subject to the terms of this DPA.
Categories of Data Subjects. Customer may submit Personal Data to the Services, the extent of which is determined and controlled by Customer in its sole discretion, and which may include, but is not limited to Personal Data relating to the following categories of data subjects:
● Customer’s customers and/or Customers
● Employees, agents, advisors, freelancers of Customer (who are natural persons)
● Employees or contact persons of Customer’s prospects, Customers, business partners and vendors
The frequency of the transfer. Continuous basis
The period for which the personal data will be retained, or, if that is not possible, the criteria used to determine that period.As described in this DPA and/or the Agreement
For transfers to (sub-) processors, also specify subject matter, nature, and duration of the processing. Asdetailed in Schedule 2.
SCHEDULE 2 – SUB-PROCESSOR LIST Entity Name - Sub-Processing Activities, Entity Country: ● Mixpanel - Monitoring and tracking logs and events, Netherlands
● Posthog - Monitoring and tracking logs and events, Germany
● Datadog - Monitoring and tracking logs and events, Germany
● Anthropic - Customer request analysis, United States
● OpenAI - Customer request analysis, United States ● Zapier - Monitoring and tracking logs and events, United States ● Sherloq Inc. - Company affiliate, United States
SCHEDULE 3 - STANDARD CONTRACTUAL CLAUSES
EU SCCs. If the Processing of Personal Data includes transfers from the EU to countries outside the EEA which do not offer adequate level of data protection or which have not been subject to an Adequacy Decision, the Parties shall comply with Chapter V of the GDPR. The Parties hereby agree to execute the Standard Contractual Clauses as follows:
a) The Standard Contractual Clauses (Controller-to-Processor and Processor to Processor) as applicable, will apply with respect to restricted transfers between Customer and Sherloq that are subject to the GDPR.
b) The Parties agree that for the purpose of transfer of Personal Data between Customer (as Data Exporter) and Sherloq (as Data Importer), the following shall apply: (i) Clause 7 of the Standard Contractual Clauses shall be applicable; (ii) In Clause 9, option 2 shall apply and the method described in Section 5 of the DPA (Authorization Regarding Sub-Processors) shall apply; (iii) The optional wording in Clause 11 of the Standard Contractual Clauses shall be not applicable; (iv) In Clause 13: the relevant option applicable to the Customer, as informed by Customer to Sherloq; (v) In Clause 17, option 1 shall apply. The Parties agree that the Standard Contractual Clauses shall be governed by the laws of Ireland; and (vi) In Clause 18(b) the Parties choose the courts of Ireland, as their choice of forum and jurisdiction.
c) Annex I.A: With respect to Module Two: (i) Data Exporter is Customer as a data controller and (ii) the Data Importer is Sherloq as a data processor. With respect to Module Three: (i) Data Exporter is Customer as a data processor and (ii) the Data Importer is Sherloq as a data processor (sub-processor). Data Exporter and Data Importer Contact details: As detailed in the Agreement. Signature and Date: By entering into the Agreement and this DPA, each Party is deemed to have signed these Standard Contractual Clauses incorporated herein, including their Annexes, as of the Effective Date of the DPA.
d) Annex I.B of the Standard Contractual Clauses shall be completed as described in Schedule 1 (Details of the Processing) of this DPA.
e) Annex I.C of the Standard Contractual Clauses shall be completed as follows: The competent supervisory authority is the Irish supervisory authority.
f) Annex II of the Standard Contractual Clauses shall be completed as described in the Security Documentation.
g) Annex III of the Standard Contractual Clauses shall be completed with the authorized sub-processors detailed in Schedule 2 (Sub-processor list) of this DPA
