1. Scope and Applicability

This Data Processing Addendum ("DPA") forms part of the Master Subscription Agreement or other written or electronic agreement between Eligant ("Provider") and the Customer ("Customer") for the purchase of online services from Eligant. This DPA applies to the extent that Eligant processes Personal Data on behalf of the Customer.

2. Processing of Personal Data

2.1 Roles of the Parties. The parties acknowledge and agree that with regard to the Processing of Personal Data, Customer is the Controller, and Eligant is the Processor.

2.2 Customer's Processing of Personal Data. Customer shall, in its use of the Services, Process Personal Data in accordance with the requirements of Data Protection Laws and Regulations.

2.3 Eligant's Processing of Personal Data. Eligant shall treat Personal Data as Confidential Information and shall only Process Personal Data on behalf of and in accordance with Customer's documented instructions.

3. Sub-processing

Eligant may engage third-party Sub-processors in connection with the provision of the Services. Eligant will maintain an up-to-date list of Sub-processors and provides this list to Customer upon request.

4. Security Measures

Eligant shall maintain appropriate technical and organizational measures for protection of the security (including protection against unauthorized or unlawful Processing and against accidental or unlawful destruction, loss or alteration or damage, unauthorized disclosure of, or access to, Customer Data), confidentiality and integrity of Customer Data.

5. International Transfers

Eligant stores and processes data primarily within secure data centers located in the United States. Any transfer of data across international borders is conducted in compliance with applicable laws.