What is the scope and term of the Data Processing Addendum?

The DPA covers Customer Personal Data, Xemplo Account Data, and Xemplo Usage Data. Xemplo processes Customer Personal Data as a Processor according to customer instructions. Xemplo processes Account Data and Usage Data as a Controller for specific purposes including providing and improving products, managing customer relationships, security, fraud prevention, and business operations.

What categories of personal data does Xemplo process?

Xemplo processes contact information, employment-related information including occupation, salary, superannuation, timesheets, tax information, job application information including CV and work history, and sensitive information such as ID documents, health information, vaccination history, and work eligibility information including visa status and criminal history.

What security measures does Xemplo implement?

Xemplo implements access control, data encryption, pseudonymization, incident response procedures, system monitoring and logging, and data backup and recovery measures to protect personal data.

Which data protection laws does Xemplo comply with?

Xemplo complies with applicable data protection laws including GDPR (Europe), UK Data Protection Law, Swiss FADP, Australian Privacy Principles (APP), CCPA and US State Privacy Laws, Brazilian data protection law, Canadian privacy law, Japanese privacy law, Singapore privacy law, and South Korean privacy law.

Does Xemplo use sub-processors?

Yes, Xemplo may engage sub-processors to process personal data. Xemplo provides notice to customers regarding sub-processors and maintains appropriate agreements with sub-processors to ensure data protection compliance.

Data Processing Addendum (DPA) | Xemplo Legal & Compliance

This Data Processing Addendum (“DPA”) supplements the Xemplo Platform Agreement, or other agreement in place between Customer and Xemplo covering Customer’s use of Xemplo’s Products and related Support and Advisory Services (the “Agreement”). Unless otherwise defined in this DPA or in the Agreement, all capitalized terms used in this DPA will have the meanings given to them in Section 9 of this DPA.

1. Scope and Term

1.1. Roles of the Parties

Customer Personal Data. Xemplo will Process Customer Personal Data as Customer’s Processor in accordance with Customer’s instructions as outlined in Section 2.1 (Customer Instructions).
Xemplo Account Data. Xemplo will Process Xemplo Account Data as a Controller for the following purposes: (i) to provide and improve the Products; (ii) to manage the Customer relationship (communicating with Customer and Users in accordance with their account preferences, responding to Customer inquiries and providing technical support, etc.), (iii) to facilitate security, fraud prevention, performance monitoring, business continuity and disaster recovery; and (iv) to carry out core business functions such as accounting, billing, and filing taxes.
Xemplo Usage Data. Xemplo will Process Xemplo Usage Data as a Controller for the following purposes: (i) to provide, optimize, secure, and maintain Xemplo’s Products; (ii) to optimize user experience; and (iii) to inform Xemplo’s business strategy.
Description of the Processing. Details regarding the Processing of Personal Data by Xemplo are stated in Schedule 1 (Description of Processing).

1.2. Term of the DPA. The term of this DPA coincides with the term of the Agreement and terminates upon expiration or earlier termination of the Agreement (or, if later, the date on which Xemplo ceases all Processing of Customer Personal Data).

1.3. Order of Precedence. If there is any conflict or inconsistency among the following documents, the order of precedence is: (1) the applicable terms stated in Schedule 2 (Region-Specific Terms including any transfer provisions); (2) the main body of this DPA; and (3) the Agreement.

2. Processing of Personal Data

2.1. Customer Instructions. Xemplo must Process Customer Personal Data in accordance with the documented lawful instructions of Customer as stated in the Agreement (including this DPA) and respective Orders, as necessary to (i) enable the use of various features and functionalities in accordance with the Documentation (including as directed by Users through the Cloud Products), (ii) provide Advisory Services or (iii) comply with its legal obligations. Xemplo will notify Customer if it becomes aware, or reasonably believes, that Customer’s instructions violate Applicable Data Protection Law.

2.2. Confidentiality. Xemplo must treat Customer Personal Data as Customer’s Confidential Information under the Agreement. Xemplo must ensure personnel authorized to Process Personal Data are bound by written or statutory obligations of confidentiality.

3. Security

3.1. Security Measures. Xemplo has implemented and will maintain appropriate technical and organizational measures designed to protect the security, confidentiality, integrity and availability of Customer Data and protect against Security Incidents. Customer is responsible for configuring the Products and using features and functionalities made available by Xemplo to maintain appropriate security in light of the nature of Customer Data. Customer acknowledges that the Security Measures are subject to technical progress and development and that Xemplo may update or modify the Security Measures from time to time, provided that such updates and modifications do not materially decrease the overall security of the Cloud Products during a Subscription Term.

3.2. Security Incidents. Xemplo must notify Customer without undue delay and, where feasible, no later than seventy-two (72) hours after becoming aware of a Security Incident. Xemplo must make reasonable efforts to identify the cause of the Security Incident, mitigate the effects and remediate the cause to the extent within Xemplo’s reasonable control. Upon Customer’s request and taking into account the nature of the Processing and the information available to Xemplo, Xemplo must assist Customer by providing information reasonably necessary for Customer to meet its Security Incident notification obligations under Applicable Data Protection Law. Xemplo’s notification of a Security Incident is not an acknowledgment by Xemplo of its fault or liability.

4. Sub-processing

4.1. General Authorization. By entering into this DPA, Customer provides general authorization for Xemplo to engage Sub-processors to Process Customer Personal Data. Xemplo must: (i) enter into a written agreement with each Sub-processor imposing data protection terms that require the Sub-processor to protect Customer Personal Data to the standard required by Applicable Data Protection Law and to the same standard provided by this DPA; and (ii) remain liable to Customer if such Sub-processor fails to fulfill its data protection obligations with regard to the relevant Processing activities under the Agreement.

4.2. Notice of New Sub-processors. Xemplo maintains an up-to-date list of its Sub-processors available on its website. Xemplo will provide such notice, to those emails subscribed, at least thirty (30) days before allowing any new Sub-processor to Process Customer Personal Data (the “Sub-processor Notice Period”).

4.3. Objection to New Sub-processors. Customer may object to Xemplo’s appointment of a new Sub-processor during the Sub-processor Notice Period. If Customer objects, Customer, as its sole and exclusive remedy, may terminate the applicable Order for the affected Cloud Product and related Support and Advisory Services in accordance with Section 11.2 (Termination for Convenience) of the Agreement.

5. Assistance and Cooperation Obligations

5.1. Data Subject Rights. Taking into account the nature of the Processing, Xemplo must provide reasonable and timely assistance to Customer to enable Customer to respond to requests for exercising a data subject’s rights (including rights of access, rectification, erasure, restriction, objection, and data portability) in respect to Customer Personal Data.

5.2. Cooperation Obligations. Upon Customer’s reasonable request, and taking into account the nature of the applicable Processing, Xemplo will provide reasonable assistance to Customer in fulfilling Customer’s obligations under Applicable Data Protection Law (including data protection impact assessments and consultations with regulatory authorities), provided that Customer cannot reasonably fulfill such obligations independently with help of available Documentation.

5.3. Third Party Requests. Unless prohibited by Law, Xemplo will promptly notify Customer of any valid, enforceable subpoena, warrant, or court order from law enforcement or public authorities compelling Xemplo to disclose Customer Personal Data. In the event that Xemplo receives an inquiry or a request for information from any other third party (such as a regulator or data subject) concerning the Processing of Customer Personal Data, Xemplo will redirect such inquiries to Customer, and will not provide any information unless required to do so under applicable Law.

6. Deletion and Return of Customer Personal Data

6.1.During Subscription Term. During the Subscription Term, Customer and its Users may, through the features of the Cloud Products, access, retrieve or delete Customer Personal Data.

6.2.Post Termination. Following expiration or termination of the Agreement, Xemplo must, in accordance with the Documentation, delete all Customer Personal Data. Notwithstanding the foregoing, Xemplo may retain Customer Personal Data (i) as required by Applicable Data Protection Law or (ii) in accordance with its standard backup or record retention policies, provided that, in either case, Xemplo will maintain the confidentiality of, and otherwise comply with the applicable provisions of this DPA with respect to retained Customer Personal Data and not further Process it except as required by Applicable Data Protection Law.

7. Audit

7.1. Audit Reports. Xemplo is regularly audited by independent third-party auditors and/or internal auditors. Upon request, and on the condition that Customer has entered into an applicable non-disclosure agreement with Xemplo, Xemplo will supply a summary copy of relevant audit report(s) (“Report”) to Customer, so Customer can verify Xemplo’s compliance with the audit standards against which it has been assessed, and this DPA. If Customer cannot reasonably verify Xemplo’s compliance with the terms of this DPA, Xemplo will provide written responses (on a confidential basis) to all reasonable requests for information made by Customer related to its Processing of Customer Personal Data, provided that such right may only be exercised no more than once every twelve (12) months.

7.2. On-site Audits. Only to the extent Customer cannot reasonably satisfy Xemplo’s compliance with this DPA through the exercise of its rights under Section 7.1 above, or where required by Applicable Data Protection Law or a regulatory authority, Customer, or its authorized representatives, may, at Customer’s expense, conduct audits (including inspections) during the term of the Agreement to assess Xemplo’s compliance with the terms of this DPA. Any audit must (i) be conducted during Xemplo’s regular business hours, with reasonable advance written notice of at least sixty (60) calendar days (unless Applicable Data Protection Law or a regulatory authority requires a shorter notice period); (ii) be subject to reasonable confidentiality controls obligating Customer (and its authorized representatives) to keep confidential any information disclosed that, by its nature, should be confidential; (iii) occur no more than once every twelve (12) months; and (iv) restrict its findings to only information relevant to Customer.

8. International Provisions

To the extent Xemplo Processes Personal Data protected by Applicable Data Protection Laws in one of the regions listed in Schedule 2 (Region-Specific Terms), the terms specified for the applicable regions will also apply, including the provisions relevant for international transfers of Personal Data (directly or via onward transfer).

9. Definitions

“Applicable Data Protection Law” means all Laws applicable to the Processing of Personal Data under the Agreement.

“Xemplo Account Data” means Personal Data relating to Customer’s relationship with Xemplo, including: (i) Users’ account information (e.g. name OR email address); (ii) billing and contact information of individual(s) associated with Customer’s Xemplo account (e.g. billing address, email address, or name); (iii) Users’ device and connection information (e.g. IP address); and (iv) content/description of technical support requests (excluding attachments).

“Xemplo Usage Data” means Personal Data relating to or obtained in connection with the use, performance, operation, support or use of the Products. Xemplo Usage Data may include event name (i.e. what action Users performed), event timestamps, browser information, and diagnostic data. For clarity, Xemplo Usage Data does not include Customer Personal Data.

“Controller” means the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the Processing of Personal Data.

“Customer Personal Data” means Personal Data contained in Customer Data and/or Customer Materials that Xemplo Processes under the Agreement solely on behalf of Customer. For clarity, Customer Personal Data includes any Personal Data included in the attachments provided by Customer or its Users in any technical support requests.

“Personal Data” means information about an identified or identifiable natural person, or which otherwise constitutes “personal data”, “personal information”, “personally identifiable information” or similar terms as defined in Applicable Data Protection Law and includes:

Contact information including residential and/or postal address, email address, telephone number, and social media handles;
Employment related information including occupation or job title, information relating to current and former employers, key dates relating to the current role and/or past roles, superannuation information, salary and/or pension details including documents such as payslips and payment summaries, timesheets, performance reviews and workplace engagement information, workplace issues and incident information citizenship and visa status for work eligibility purposes, emergency contact information, and tax information;
Job application related information including CV, cover letter, profile photo, work preferences, salary expectations, education history, work history, qualifications, languages, and references; and

the following special categories of Personal Data:

sensitive information provided in compliance documentation stored on the Services by the Customer or end-users;
ID documents and information provided within such documents that may include details about ethnicity or race, religious beliefs;
health information such as disability information, health status relevant to administration of long-term disability or other medical benefit programs, vaccination history, medical reports, return or work/adjustment reports and workplace injury reports; and
work eligibility information such as immigration status, visa status and details, and criminal history and background.

“Processing” (and “Process”) means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated 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.

“Processor” means the entity which Processes Personal Data on behalf of the Controller.

“Security Incident” means any breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Customer Data Processed by Xemplo and/or its Sub-processors.

“Sub-processor” means any third party (inc. Xemplo Affiliates) engaged by Xemplo to Process Customer Personal Data.

1. Categories of data subjects whose Personal Data is Processed: Customer and its Users.

2. Categories of Personal Data Processed: Xemplo Account Data, Xemplo Usage Data, and Customer Personal Data.

‍3. Sensitive data transferred: Xemplo Account Data and Customer Usage Data do not contain data (i) revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, (ii) genetic data, biometric data Processed for the purposes of uniquely identifying a natural person, data concerning health, or data concerning a natural person’s sex life or sexual orientation, or (iii) relating to criminal convictions and offences (altogether “Sensitive Data”). Subject to Section 6.3 of the Agreement (Sensitive Health Information and HIPAA), Customer or its Users may upload content to the Cloud Products which may include Sensitive Data, the extent of which is determined and controlled solely by Customer.

‍4. The frequency of the transfer: Continuous.

‍5. Nature of the Processing: Xemplo will Process Personal Data in order to provide the Products and related Support and Advisory Services in accordance with the Agreement, including this DPA. Additional information regarding the nature of the Processing (including transfer) is described in respective Orders for relevant Products and Documentation referring to technical capabilities and features, including but not limited to collection, structuring, storage, transmission, or otherwise making available of Personal Data by automated means.

‍6. Purpose(s) of the Processing:

‍6.1. Customer Personal Data: Xemplo will Process Customer Personal Data as Processor in accordance with Customer’s instructions as set out in Section 2.1 (Customer Instructions).

6.2. Xemplo Account Data and Xemplo Usage Data: Xemplo will Process Xemplo Account Data and Xemplo Usage Data for the limited and specified purposes outlined in Section 1.1 (Roles of the Parties).

7. Duration of Processing:

‍7.1. Customer Personal Data: Xemplo will Process Customer Personal Data for the term of the Agreement as outlined in Section 6 (Deletion and Return of Customer Personal Data).

7.2. Xemplo Account Data and Xemplo Usage Data: Xemplo will Process Xemplo Account Data and Xemplo Usage Data only as long as required (a) to provide Products and related Support and Advisory Services to Customer in accordance with the Agreement; (b) for Xemplo’s legitimate business purposes outlined in Section 1.1 (Roles of the Parties); or (c) by applicable Law(s).

8. Transfers to (Sub-)processors: Xemplo will transfer Customer Personal Data to Sub-processors as permitted in Section 4 (Sub- processing).

Unless otherwise defined in this DPA or in the Agreement, all capitalized terms used in this Schedule will have the meanings given to them in Section 4 of this Schedule.

1. Europe, United Kingdom and Switzerland.

‍1.1. Customer Instructions. In addition to Section 2.1 (Customer Instructions) of the DPA above, Xemplo will Process Customer Personal Data only on documented instructions from Customer, including with regard to transfers of such Customer Personal Data to a third country or an international organisation, unless required to do so by Applicable Data Protection Law to which Xemplo is subject; in such a case, Xemplo shall inform Customer of that legal requirement before Processing, unless that law prohibits such information on important grounds of public interest. Xemplo will promptly inform Customer if it becomes aware that Customer’s Processing instructions infringe Applicable Data Protection Law.

1.2. European Transfers. Where Personal Data protected by the EU Data Protection Law is transferred, either directly or via onward transfer, to a country outside of Europe that is not subject to an adequacy decision, the following applies:

(a)The EU SCCs are hereby incorporated into this DPA by reference as follows:

(i)Customer is the “data exporter” and Xemplo is the “data importer”.
(ii)Module One (Controller to Controller) applies where Xemplo is Processing Xemplo Account Data or Xemplo Usage Data.
(iii)Module Two (Controller to Processor) applies where Customer is a Controller of Customer Personal Data and Xemplo is Processing Customer Personal data as a Processor.
(iv)Module Three (Processor to Processor) applies where Customer is a Processor of Customer Personal Data and Xemplo is Processing Customer Personal Data as another Processor.
(v)By entering into this DPA, each party is deemed to have signed the EU SCCs as of the commencement date of the Agreement.

(b)For each Module, where applicable:

(i) In Clause 7, the optional docking clause does not apply.
(ii) In Clause 9, Option 2 applies, and the time period for prior notice of Sub-processor changes is stated in Section 4 (Sub- processing) of this DPA.
(iii) In Clause 11, the optional language does not apply.(iv)In Clause 17, Option 1 applies, and the EU SCCs are governed by Irish law.
(v) In Clause 18(b), disputes will be resolved before the courts of Ireland.
(vi) The Appendix of EU SCCs is populated as follows:
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The information required for Annex I(A) is located in the Agreement and/or relevant Orders.
The information required for Annex I(B) is located in Schedule 1 (Description of Processing) of this DPA.
The competent supervisory authority in Annex I(C) will be determined in accordance with the Applicable Data Protection Law; and
The information required for Annex III is located in Schedule 3.

(b) In Table 4 of the UK Addendum, both the data importer and data exporter may end the UK Addendum.

1.5. Data Privacy Framework: Xemplo participates in and certifies compliance with the Data Privacy Framework. As required by the Data Privacy Framework, Xemplo (i) provides at least the same level of privacy protection as is required by the Data Privacy Framework Principles; (ii) will notify Customer if Xemplo makes a determination it can no longer meet its obligation to provide the same level of protection as is required by the Data Privacy Framework Principles, and (iii) will, upon written notice, take reasonable and appropriate steps to remediate any unauthorized Processing of Personal Data.

2. United States of America. The following terms apply where Xemplo Processes Personal Data subject to the US State Privacy Laws:

2.1. To the extent Customer Personal Data includes personal information protected under US State Privacy Laws that Xemplo Processes as a Service Provider or Processor, on behalf of Customer, Xemplo will Process such Customer Personal Data in accordance with the US State Privacy Laws, including by complying with applicable sections of the US State Privacy Laws and providing the same level of privacy protection as required by US State Privacy Laws, and in accordance with Customer’s written instructions, as necessary for the limited and specified purposes identified in Section 1.1(a) (Customer Personal Data) and Schedule 1 (Description of Processing) of this DPA. Xemplo will not:

(a) retain, use, disclose or otherwise Process such Customer Personal Data for a commercial purpose other than for the limited and specified purposes identified in this DPA, the Agreement, and/or any related Order, or as otherwise permitted under US State Privacy Laws;
(b) “sell” or “share” such Customer Personal Data within the meaning of the US State Privacy Laws; and
(c)retain, use, disclose or otherwise Process such Customer Personal Data outside the direct business relationship with Customer and not combine such Customer Personal Data with personal information that it receives from other sources, except as permitted under US State Privacy Laws.

2.2. Xemplo must inform Customer if it determines that it can no longer meet its obligations under US State Privacy Laws within the timeframe specified by such laws, in which case Customer may take reasonable and appropriate steps to prevent, stop, or remediate any unauthorized Processing of such Customer Personal Data.

2.3. To the extent Customer discloses or otherwise makes available Deidentified Data to Xemplo or to the extent Xemplo creates Deidentified Data from Customer Personal Data, in each case in its capacity as a Service Provider, Xemplo will:

(a) adopt reasonable measures to prevent such Deidentified Data from being used to infer information about, or otherwise being linked to, a particular natural person or household;
(b) publicly commit to maintain and use such Deidentified Data in a de-identified form and to not attempt to re-identify the Deidentified Data, except that Xemplo may attempt to re-identify such data solely for the purpose of determining whether its de-identification processes are compliant with the US State Privacy Laws; and
(c) before sharing Deidentified Data with any other party, including Sub-processors, contractors, or any other persons (“Recipients”), contractually obligate any such Recipients to comply with all requirements of this Section 2.3 (including imposing this requirement on any further Recipients).

3. South Korea.

‍3.1. Customer agrees that it has provided notice and obtained all consents and rights necessary under Applicable Data Protection Law for Xemplo to Process Xemplo Account Data and Xemplo Usage Data pursuant to the Agreement (including this DPA).

3.2. To the extent Customer discloses or otherwise makes available Deidentified Data to Xemplo, x will:

(a)maintain and use such Deidentified Data in a de-identified form and not attempt to re-identify the Deidentified Data; and
(b)before sharing Deidentified Data with any other party, including Sub-processors, contractors, or any other persons (“Recipients”), contractually obligate any such Recipients to comply with all requirements of this Section 3.2 (including imposing this requirement on any further Recipients).

4.Definitions.

‍4.1 Where Personal Data is subject to the laws of one the following regions, the definition of “Applicable Data Protection Law” includes:

(a) Australia: the Australian Privacy Act;

(b) Brazil: the Brazilian Lei Geral de Proteção de Dados (General Personal Data Protection Act);

(c) Canada: the Canadian Personal Information Protection and Electronic Documents Act;

(d) Europe: (i) the Regulation 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the Processing of Personal Data and on the free movement of such data (General Data Protection Regulation, or GDPR) and (ii) the EU e-Privacy Directive (Directive 2002/58/EC) as amended, superseded or replaced from time to time (“EU Data Protection Law”);

(e) Japan: the Japanese Act on the Protection of Personal Information

(f) Singapore: the Singapore Personal Data Protection Act;

(g) South Korea: the South Korean Personal Information Protection Act (“PIPA”) and the Enforcement Decrees of PIPA;

(h) Switzerland: the Swiss Federal Act on Data Protection and its implementing regulations as amended, superseded, or replaced from time to time (“Swiss FADP”);

(i) The United Kingdom: the Data Protection Act 2018 and the GDPR as saved into United Kingdom law by virtue of Section 3 of the United Kingdom’s European Union (Withdrawal) Act 2018 as amended, superseded or replaced from time to time (“UK Data Protection Law”); and

(j) The United States: all state laws relating to the protection and Processing of Personal Data in effect in the United States of America, which may include, without limitation, the California Consumer Privacy Act, as amended by the California Privacy Rights Act, and its implementing regulations (“CCPA”), the Virginia Consumer Data Protection Act, the Colorado Privacy Act, the Connecticut Data Privacy Act, and the Utah Consumer Privacy Act (“US State Privacy Laws”).

4.2 “Deidentified Data” means data that cannot reasonably be used to infer information about, or otherwise be linked to, a data subject.

4.3“Data Privacy Framework” means the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Framework self-certification program operated by the US Department of Commerce.

4.4“Europe” includes, for the purposes of this DPA, the Member States of the European Union and European Economic Area.

4.5“EU SCCs” means the contractual clauses annexed to the European Commission’s Implementing Decision 2021/914 of 4 June 2021 on standard contractual clauses for the transfer of Personal Data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council, as amended, superseded, or replaced from time to time.

4.6“Service Provider” has the same meaning as given in the CCPA.

4.7“UK Addendum” means the International Data Transfer Addendum to the EU Commission Standard Contractual Clauses issued by the UK Information Commissioner, Version B1.0, in force 21 March 2022, as amended, superseded or replaced from time to time.
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Access Control
Access Control to Premises and Facilities: Measures to prevent unauthorized persons from gaining access to data processing systems (e.g., secure entry points, surveillance systems).
Access Control to Systems: Measures to ensure that persons entitled to use a data processing system gain access only to the data to which they have a right of access (e.g., unique user IDs, password policies, two-factor authentication).

‍Data Encryption
‍In Transit: Data is encrypted during transmission using industry-standard protocols such as TLS.At Rest: Data is encrypted at rest using advanced encryption standards (e.g., AES-256).

‍Pseudonymization
‍Data Minimization: Personal data is processed, where possible, in a way that no longer permits the identification of data subjects without the use of additional information, which is kept separately and subject to technical and organizational measures.

‍Incident Response
‍Procedures: Established procedures for detecting, reporting, and responding to data breaches (e.g., incident response plan, regular training for employees).

‍System Monitoring and Logging
‍Monitoring: Continuous monitoring of systems to detect potential vulnerabilities and security incidents.
Logging: Keeping detailed logs of access and changes to data, reviewed regularly to detect unauthorized activities.

‍Data Backup and RecoveryRegular Backups: Regular backups of data to ensure availability and integrity in case of an incident.
Recovery Procedures: Procedures in place to restore the availability and access to personal data in a timely manner following a physical or technical incident.

Xemplo Data Processing Addendum