Sub Processor Agreement

1.1.10 „subprocessor“ refers to any person mandated by or on behalf of the subcontractor to process personal data on behalf of the company in connection with the agreement. ☐ the subcontractor may only order a subcontractor with the prior authorization of the processing manager and under a written contract; (i) that, in the case of a subcontract in point 11, the processing activity is carried out by a subcontractor offering at least the same level of protection for personal data and the rights of the person concerned as the importer of data in accordance with the clauses; and ☐ the subcontractor can only act on the documented instructions of the person in charge of the treatment, unless required by law, without such instructions being taken; 3.4 Subcontractors and transfers to third countries „Convention“ refer to Mailchimp`s Terms of Use or any other written or electronic agreement that governs the provision of service to the customer, as these terms or agreements may be updated from time to time. In accordance with the privacy policy, a subscriber may, within 30 days of the update of this Directive, object in writing to the processing of his personal data by a new subprocessor and describe the legitimate reasons for the objection. If the subscriber is not contradicted during this period, the new subprocessor (s) is considered presumed. 4.1 Wolters Kluwer provides the customer with all the information necessary to prove compliance with the requirements of applicable data protection legislation for subcontractors and to enable and conduct audits, including inspections, carried out by the processing managers or by any other controller in charge of processing. If a processing manager wishes to conduct an inspection, the processing manager, Wolters Kluwer, must provide appropriate notice, while indicating the content and scope of the inspection. Wolters Kluwer can charge the customer any reasonable costs associated with the audit. 18.1 Amendments. The terms of this agreement can only be changed by a written agreement between the parties. For all subscribers who have performed Ethnio`s standard DPA, Ethnio will be informed of this directive on updates to the list of subprocessors used or will use Ethnio to provide its services.

Ethnio undertakes to keep this list up to date on a regular basis to keep its subscribers informed of the extent of the sub-treatment associated with ethnio services.