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SupportBetween: ClickSambo OÜ, doing business as ClickSambo ("ClickSambo"), and its Customer ("Customer").
Effective Date: 24 November 2024
Affiliate: An entity directly or indirectly controlling, controlled by, or under common control with another entity. Control means an ownership, voting, or similar interest representing 50% or more of the total outstanding interests of the entity.
Authorized Affiliate: Any of Customer's Affiliates permitted to receive ClickSambo's services.
ClickSambo Data: Data relating to and/or obtained in connection with the operation, support, and/or use of ClickSambo's services. ClickSambo is the controller of this data.
ClickSambo Services: The products and services ClickSambo provides to the Customer.
Controller: The entity determining the purposes and means of processing Personal Data.
Customer Data: Any data ClickSambo processes on behalf of the Customer in providing its services.
Data Protection Laws: All applicable data protection and privacy laws and regulations, including but not limited to the GDPR, and any relevant national or international laws.
Personal Data: Any Customer Data relating to an identified or identifiable natural person, protected as personal data under applicable Data Protection Laws.
Processor: An entity processing Personal Data on behalf of the Controller.
Processing: Any operation or set of operations performed on Personal Data.
Security Incident: Any unauthorized or unlawful breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data.
Sub-processor: Any processor engaged by ClickSambo to assist in providing its services.
This DPA applies where ClickSambo processes Personal Data on behalf of the Customer, and such Personal Data is subject to Data Protection Laws. ClickSambo acts as a processor, and the Customer is the controller of the Personal Data.
ClickSambo retains the right to use its own independently collected data for its legitimate business purposes.
The Customer agrees to:
∗Comply with its obligations as a Controller under Data Protection Laws.
∗Obtain all necessary consents and rights under Data Protection Laws for ClickSambo to process Personal Data and provide services.
ClickSambo will process Customer Data for the purposes of providing, maintaining, and improving its services, providing customer and technical support, and fulfilling legal obligations.
ClickSambo will not process sensitive Personal Data without explicit consent from the Customer.
ClickSambo may use sub-processors. A list of current sub-processors will be maintained and updated on Clicksambo's website.
The Customer has the right to object to new sub-processors on reasonable data protection grounds, and the parties will discuss such concerns in good faith.
ClickSambo will implement appropriate technical and organizational security measures to protect Personal Data from Security Incidents.
In the event of a Security Incident, ClickSambo will notify the Customer without undue delay.
ClickSambo will maintain records of its security standards and provide relevant documentation to the Customer upon written request, within the bounds of reasonable requests.
ClickSambo will comply with all applicable Data Protection Laws regarding the transfer of Personal Data to countries outside of the EEA. Appropriate safeguards will be implemented for all data transfers.
Upon termination of services, ClickSambo will delete Personal Data unless required by law to retain it. Archived data will be securely isolated.
∗ClickSambo will cooperate with the Customer to respond to data subject requests and data protection authority inquiries.
∗ClickSambo will not respond directly to such requests without Customer authorization, unless legally compelled to do so.
This DPA is an addendum to the Terms of Service. In case of conflict, this DPA prevails.
No party limits its liability with respect to any individual's data protection rights.
Governing law and jurisdiction will be specified in the Terms of Service, unless otherwise required by Data Protection Laws.
This DPA may be amended by mutual written agreement of both parties.
This DPA is effective as of the date listed above and is subject to change. It is recommended to review this document periodically for any updates.
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