Data Processing Addendum

1. Data Processing Addendum

This Data Processing Addendum ("DPA") forms an integral part of the agreement between the customer, as data controller, and CloviTek Inc., as data processor. It establishes the mutual terms governing data processing activities, outlines required technical and organizational security measures, defines procedures for engaging sub-processors, and ensures compliance with applicable data protection laws through appropriate international transfer safeguards.

High-stakes: processor obligations require attorney review.

2. Authorized Sub-processors

CloviTek Inc. engages external vendors as sub-processors to support service delivery and data handling. All sub-processors are documented in our maintained inventory and are contractually bound to implement data protection and security obligations no less rigorous than those set forth herein. Any updates to the sub-processor list will be tracked and communicated in accordance with the notice provisions of the master agreement, ensuring operational transparency and regulatory compliance.