Terms of service

§ 1. General provisions

1. Introduction

These Senvio Terms of Service (the “Terms”) set out the conditions on which software is made available under a SaaS (Software as a Service) model and services are provided by electronic means by SORVE spółka z ograniczoną odpowiedzialnością, with its registered office in Warsaw, al. „Solidarności” 68/121, 00-240 Warszawa, entered in the register of entrepreneurs of the National Court Register kept by the District Court for the Capital City of Warsaw in Warsaw, 12th Commercial Division of the National Court Register, under KRS number 0001251512, NIP 5253096470, REGON 545200116, with a share capital of PLN 5,000.00, e-mail address: kontakt@senvio.ai, operating under the Senvio brand (the “Service Provider”).

An integral part of the Terms is the appendix, i.e. the Personal Data Processing Agreement, as well as the terms of promotional campaigns published on the Website. By accepting the Terms, the Customer agrees to their content.

2. Definitions

Capitalised expressions used in the Terms have the following meaning, whereby references to terms in the singular also include their use in the plural and vice versa:

• Terms – this document setting out the rules for using the Services and the conditions for concluding, performing and terminating Agreements between the Service Provider and the Customer.
• Service Provider – SORVE spółka z ograniczoną odpowiedzialnością with its registered office in Warsaw, operating under the Senvio brand, indicated in §1 of the Terms.
• Customer – an entity conducting business activity which has concluded an Agreement with the Service Provider and uses the Services, irrespective of the legal form of the activity conducted.
• Agreement – the agreement for the provision of Services by electronic means concluded between the Service Provider and the Customer, an integral part of which is formed by the Terms and the documents referred to in §1 of the Terms.
• System – the Senvio software made available under the Software as a Service (SaaS) model, comprising the online platform, technical infrastructure, algorithms, analytical models, artificial intelligence (AI) based solutions, the user interface, the API and the documentation.
• Services – the services provided by the Service Provider by electronic means, consisting in particular in enabling the Customer to use the System, its features and the Output generated by it.
• Account – the Customer's individual account created in the System, enabling access to the Services, management of the Subscription and use of the System's features.
• Subscription – paid access to the Services for a definite period, in accordance with the selected subscription plan, the price list or individual commercial terms.
• Subscription Plan – a defined variant of the Subscription covering the range of features, the limits, the level of access and the financial conditions.
• Customer Data – all data, information, content or materials entered into the System by the Customer or on the Customer's behalf, irrespective of their form or nature.
• Output – analyses, reports, recommendations, forecasts, comparisons, summaries, benchmarks and other results generated by the System on the basis of Customer Data or data processed in the System.
• Artificial Intelligence (AI) – the machine learning algorithms and the statistical, predictive and heuristic models used in the System, operating in a probabilistic and non-deterministic manner.
• Aggregated Data – statistical, operational or sales data arising from the anonymisation and aggregation of data processed in the System, which does not make it possible to identify the Customer, the Customer's clients or any natural persons.
• Benchmarks – studies, comparisons, market analyses or reports prepared on the basis of Aggregated Data.
• Third-Party Services – services, systems, platforms or APIs of third parties with which the System may be integrated or whose data it may use.
• Price List – the current schedule of fees for the Services, subscription plans and financial conditions, published by the Service Provider or agreed individually with the Customer.
• Business Day – a day from Monday to Friday between 9:00 and 17:00 local time in Poland, excluding days that are public holidays in the Republic of Poland.

3. Representations of the Customer and its representatives

3.1. Upon conclusion of the Agreement the Customer confirms that it has read the content of the Terms and the related documents, understands their meaning, and that it is entitled to conclude the Agreement and to use the Services in a manner consistent with their provisions.

3.2. Where the actions connected with concluding the Agreement are taken by a person acting on behalf of the Customer, that person declares that they hold appropriate authorisation to represent the Customer, and that the scope of that authorisation covers concluding the Agreement and performing the actions connected with using the Services.

3.3. The Services offered by the Service Provider are intended solely for entities conducting business or professional activity. By accepting the Terms, the Customer confirms that it is concluding the Agreement within the scope of its activity and that it is not using the Services as a consumer.

3.4. The Customer undertakes to use the System and the Services in a manner consistent with the law, the Terms and their intended purpose; in particular the Customer undertakes to:

• (a) bear full responsibility for the manner in which the System is used, including for the acts and omissions of persons to whom it has granted access to the Account or the System,
• (b) use the System solely in connection with the business or professional activity it conducts, including for the purposes of its own business processes or as part of providing services to third parties, insofar as this is consistent with the Agreement and the law,
• (c) refrain from using the System, its features, the Output or data originating from the System for the purpose of conducting activity competing with the Service Provider, including in particular for the purpose of reselling access to the System, offering services of a similar nature or creating competing solutions,
• (d) ensure that the data provided within the Account is true, complete and up to date, and to update it in the event of change,
• (e) refrain from entering, storing or making available in the System any content or data that is unlawful, infringes the rights of third parties, is contrary to good practice or breaches the provisions of the Terms.

3.5. The Customer is liable to the Service Provider for any damage, claims or consequences arising from a breach of the provisions of this point, including breaches committed by persons acting on its behalf or for its benefit.

§ 2. Electronic services and the System

1. Using the System

1.1. The Customer acknowledges that the System is a technological solution based wholly or partly on artificial intelligence algorithms, statistical models and machine learning mechanisms, which operate in a non-deterministic and probabilistic manner.

1.2. The Output generated by the System may differ depending on the quality, scope, completeness and currency of the Customer Data, as well as on technological, market or contextual changes.

1.3. The Service Provider does not warrant that the Output will meet the Customer's individual expectations or business objectives.

1.4. The System does not constitute an advisory tool within the meaning of the law, and the Output does not constitute legal, financial, investment, tax or any other professional advice.

1.5. The Customer bears sole responsibility for assessing whether it is justified to use the Output and for the decisions taken on its basis.

2. Subscription and access to the Services

2.1. Access to the System takes place under a Subscription to the selected Subscription Plan, in accordance with the current Price List or the individual commercial arrangements concluded between the Parties.

2.2. The Service Provider may, at its own discretion, make available the possibility of testing the System free of charge before activating a paid Subscription. The trial period, its length, the range of features available and the conditions of use are determined each time on the Website and may change or be withdrawn at any time.

2.3. After the trial period ends, continued use of the System requires the activation of a paid Subscription, unless the Service Provider decides otherwise.

2.4. The Subscription is concluded for a definite period and renews automatically for successive billing periods, unless it is terminated in accordance with the Terms.

2.5. The Service Provider is entitled to change:

• (a) the amount of the fees,
• (b) the scope of the Subscription Plans,
• (c) the feature limits,
• (d) the billing model or the structure of the offer.

2.6. The changes referred to in point 2.3. apply from the next billing period, after the Customer has first been informed of the planned change in the manner provided for in the Terms.

2.7. The changes referred to in point 2.3. do not concern Subscriptions paid for in advance and do not affect the conditions in force during the current, paid billing period.

2.8. Failure to cancel the Subscription before the start of the next billing period constitutes acceptance of the changes referred to in point 2.3.

2.9. The Service Provider may temporarily restrict access to the System or its features in order to:

• (a) carry out technical or development work,
• (b) ensure the security or stability of the System,
• (c) prevent abuse or breaches of the Terms.

§ 3. Privacy and security

1. Customer Data

1.1. The Customer declares that it holds all rights to the Customer Data entered into the System and that its processing takes place in accordance with the applicable law.

1.2. The Service Provider does not verify the legality, completeness or truthfulness of the Customer Data and is not liable for the consequences of its use by the Customer.

1.3. The Customer bears full responsibility for:

• (a) the content of the Customer Data,
• (b) the manner of its use,
• (c) the legal, business and operational consequences of its processing.

1.4. As regards personal data, the Service Provider acts as a processor on the basis of a separate data processing agreement (DPA).

2. Analytics

2.1. The Service Provider is entitled to process information and data connected with the Customers' use of the System, in particular data of a sales, operational or statistical nature (e.g. relating to transaction volume, the number of products, customers, events or other business parameters), excluding personal data, for the purpose of carrying out analyses, statistics and development work.

2.2. The data referred to in point 7.1. is used solely in aggregated and anonymised form, in a manner that makes it impossible to identify a particular Customer, its clients or other natural persons.

2.3. The Service Provider may make the results of analyses, reports or summaries created on the basis of the data referred to above available to third parties, including business partners or cooperating entities, solely in aggregated form which does not allow the data to be attributed to particular Customers.

2.4. The restrictions referred to in this point do not apply where:

• (a) the data is made available at the express request of the Customer, or
• (b) it is necessary for the proper settlement of accounts between the Service Provider and providers of external services, integrations, technical infrastructure or other entities involved in the provision of the Services.

2.5. All analyses, reports, summaries and other studies created on the basis of the data referred to in this point constitute the exclusive property of the Service Provider.

3. References

3.1. Upon conclusion of the Agreement or commencement of the use of the Services, the Customer grants the Service Provider non-exclusive, free-of-charge and perpetual consent to use its name (business name), logo and information about the cooperation for marketing, sales, informational and reference purposes.

3.2. The consent covers in particular the possibility of presenting the Customer as a client or business partner of the Service Provider, including in marketing materials, commercial offers, presentations, reports, case studies and on websites and social media.

3.3. The consent applies without territorial restrictions and also after the Agreement has ended, and its withdrawal takes effect only for the future and does not affect the lawfulness of the earlier use of the Customer's marks.

§ 4. Intellectual property

1. Rights to the System

1.1. All intellectual property rights to the System, including to the code, algorithms, artificial intelligence models, interfaces, documentation and Output, vest solely in the Service Provider.

1.2. The Customer is entitled solely to a limited, non-exclusive and non-transferable right to use the System to the extent resulting from the Terms and the Subscription held.

1.3. In particular, it is prohibited to:

• (a) decompile, reverse engineer or copy the System,
• (b) create competing solutions,
• (c) use the System in a manner contrary to its intended purpose.

§ 5. Liability

1. Nature of the services

1.1. The Services are provided under a SaaS model, on an “as is” and “as available” basis, with the due care appropriate to a professional provider of technology services. The Service Provider does not warrant that the System will operate uninterrupted, free from errors or fully adapted to the Customer's individual expectations.

2. No warranty of results

2.1. The Service Provider does not warrant that any particular business, sales or operational results will be achieved in connection with the use of the System, in particular where the Output is generated using artificial intelligence algorithms.

2.2. Decisions taken on the basis of the Output belong solely to the Customer and are taken at the Customer's own risk.

3. Exclusion of liability

3.1. The Service Provider is not liable for:

• (a) lost profits (lucrum cessans),
• (b) indirect, consequential or resulting damage,
• (c) interruptions in the Customer's business activity,
• (d) decisions, acts or omissions of the Customer taken on the basis of the Output,
• (e) acts or omissions of third parties, including providers of external services, integrations, IT infrastructure or payment operators,
• (f) data, content or information entered into the System by the Customer or persons acting on its behalf.

5. Force Majeure

5.1. The Service Provider is not liable for non-performance or improper performance of the Services caused by an event of Force Majeure.

5.2. Force Majeure means external events, impossible to foresee and beyond the control of the Parties, in particular: natural disasters, failures of telecommunications or power infrastructure, cyber attacks, acts of public authorities, wars, riots, strikes or epidemics.

§ 6. Complaints

1. Rules for submitting complaints

1.1. The Customer is entitled to submit complaints concerning the manner in which the Services are provided or the functioning of the System.

1.2. Complaints may be submitted solely through the Customer Panel or electronically to the e-mail address indicated by the Service Provider. Submissions made in any other form will not be treated as complaints within the meaning of the Terms.

1.3. A complaint should contain at least:

• (a) a description of the problem reported together with the circumstances in which it arose,
• (b) an indication of the feature or Service to which the complaint relates,
• (c) the date on which the problem arose or the moment it was identified,
• (d) data identifying the Customer.

Incomplete complaints may be left without consideration.

1.4. The Service Provider may ask the Customer to supplement the complaint or to provide additional information necessary for its consideration. Failure to provide the required information within the time limit indicated by the Service Provider entitles the Service Provider to refuse to consider the complaint further.

1.5. A complaint should be submitted no later than within 30 days from the day on which the event forming the basis of the complaint occurred or from the day on which the Customer could have become aware of it.

1.6. The Service Provider considers a complaint within up to 30 Business Days from the day it is received, subject to point 10.4. The Customer is informed of the manner in which the complaint has been dealt with by electronic means.

1.7. Submitting a complaint does not suspend the obligation to pay the fees due to the Service Provider, nor does it affect the continuity of the provision of the Services.

1.8. Complaints may not concern:

• (a) expected business results,
• (b) the quality, accuracy or effectiveness of the Output generated by the System,
• (c) decisions taken by the Customer on the basis of the Output,
• (d) changes to the features of the System of which the Customer has been informed.

1.9. Once the complaints procedure has been exhausted, the Customer has the right to pursue any claims under general rules.

§ 7. Termination of the Agreement

1. Rules for terminating the Agreement

1.1. The Agreement is in force for the duration of an active Subscription and may be terminated by the Customer at any time by cancelling the Subscription solely through the Customer Panel, available after logging in to the Customer's Account.

1.2. Cancelling the Subscription in any way other than that indicated in point 11.1., in particular by e-mail, by telephone, through the contact form or by messages sent through other communication channels, produces no legal effect and is not equivalent to terminating the Agreement.

1.3. Effect of cancelling the Subscription:

• (a) Cancelling the Subscription stops it renewing further,
• (b) access to the System and the Services is maintained until the end of the paid billing period, irrespective of the moment the Subscription is cancelled,
• (c) once the billing period has elapsed, access to the System is automatically ended.

1.4. Fees paid by the Customer for the Subscription, irrespective of its type (monthly or annual), are not refundable, in whole or in part, in particular where the Subscription is cancelled before the end of the paid billing period; the Customer acknowledges that the absence of refunds forms part of the Service Provider's billing model and has been taken into account in the price of the Subscription.

1.5. The ending of the Agreement, whatever the reason, does not affect the applicability of those provisions of the Terms which, by their nature, should also apply after its termination, in particular the provisions concerning:

• (a) liability,
• (b) intellectual property,
• (c) aggregated data and analyses,
• (d) governing law and jurisdiction.

1.6. The Service Provider reserves the right to terminate the Agreement with immediate effect in the event of a material breach of the Terms by the Customer, in particular in the case of:

• (a) using the System in a manner contrary to the applicable law or the Terms,
• (b) infringement of the Service Provider's intellectual property rights,
• (c) taking actions that threaten the security, integrity or stability of the System,
• (d) the Customer taking actions that infringe the personal rights, reputation or image of the Service Provider, in particular by disseminating untrue, misleading or defamatory information, making threats, attempting to exert pressure or blackmail, as well as taking actions constituting acts of unfair competition or aimed at causing the Service Provider material or non-material damage, including actions that are unlawful or contrary to the principles of community life.

§ 8. Final provisions

1. Period of validity

1.1. The Terms bind the Parties throughout the period in which the Customer uses the Services, and after the Agreement ends also to the extent resulting from the nature of the Parties' rights and obligations, in particular until the limitation periods for any claims connected with the Terms or the Agreement have expired.

1.2. The Service Provider reserves the right to amend the Terms at any time, in particular in the event of changes in the law, technological or organisational changes, or the development of the System's features.

1.3. Amendments to the Terms are published on the Website or made available to the Customer by means of electronic communication.

1.4. Amendments come into force on the date indicated by the Service Provider, but no earlier than 14 days after they are made available. Continued use of the System after the amendments come into force constitutes their acceptance.

1.5. If the Customer does not accept the amendments, it is obliged to stop using the Services and to cancel the Subscription before the amendments come into force.

1.6. The Service Provider is entitled to transfer the rights and obligations arising from the Agreement or the Terms to a third party without the need to obtain the Customer's consent, provided that this does not infringe the Customer's material rights.

2. Partial invalidity

2.1. If any of the provisions of the Terms is found to be invalid, ineffective or unenforceable, this does not affect the validity of the remaining provisions of the Terms, which remain in force. The Parties undertake to replace such a provision with another which reflects, to the greatest possible extent, the original economic and legal purpose of the invalid provision.

3. Governing law and jurisdiction

3.1. The law of the Republic of Poland applies to the Terms and to the Agreement.

3.2. Any disputes arising from the Terms, the Agreement or connected with the use of the Services will be settled by the common court having local jurisdiction over the registered office of the Service Provider.

4. B2B character

4.1. The Customer confirms that it is neither a consumer nor an entrepreneur with consumer rights within the meaning of the applicable law, and that the Agreement is concluded solely within the scope of business or professional activity.

Appendix No. 1

Personal Data Processing Agreement (the “Agreement”)

This Personal Data Processing Agreement is concluded between:

the Customer – the entity using the System on the basis of the Terms, being the controller of personal data within the meaning of the GDPR (the “Controller”)

and

SORVE spółka z ograniczoną odpowiedzialnością, with its registered office in Warsaw, al. „Solidarności” 68/121, 00-240 Warszawa, entered in the register of entrepreneurs of the National Court Register kept by the District Court for the Capital City of Warsaw in Warsaw, 12th Commercial Division of the National Court Register, under KRS number 0001251512, NIP 5253096470 (the “Processor”)

The Controller and the Processor are referred to jointly as the “Parties” and each individually as a “Party”.

1. Subject of the Agreement

1.1. The subject of the Agreement is the entrustment by the Controller to the Processor of the processing of personal data, in accordance with Article 28(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the “GDPR”).

1.2. The Processor undertakes to process personal data solely on behalf of the Controller and in accordance with its documented instructions, for the purpose, within the scope and on the terms set out in this Agreement and in the Terms.

2. Scope and purpose of processing

2.1. The processing of personal data by the Processor takes place solely to the extent necessary to:

• (a) provide the Services under the SaaS model,
• (b) ensure the correct operation of the System,
• (c) fulfil the Subscription,
• (d) provide technical handling and support,
• (e) develop and improve the features of the System – subject to the provisions of point 4.4.

2.2. The Processor is not entitled to process personal data for any purpose other than that indicated above.

3. Type of data and categories of persons

3.1. The entrustment may cover in particular the following categories of personal data:

• (a) identification data,
• (b) contact data,
• (c) transactional and accounting data,
• (d) technical and system data (including logs, IP addresses, metadata).

3.2. The data concerns in particular:

• (a) users of the System,
• (b) employees or associates of the Controller,
• (c) clients of the Controller (if they are processed as part of the Services).

3.3. The Processor does not process personal data of the special categories referred to in Article 9 of the GDPR, nor data relating to criminal convictions, unless the Parties agree otherwise separately and in writing and ensure appropriate legal bases.

4. Obligations of the Processor

4.1. The Processor undertakes in particular to:

• (a) process personal data solely on the documented instruction of the Controller;
• (b) ensure the confidentiality of personal data;
• (c) allow only persons holding the appropriate authorisations to process the data and subject those persons to an obligation of confidentiality;
• (d) apply appropriate technical and organisational measures in accordance with Article 32 of the GDPR;
• (e) maintain a register of authorisations and document processing activities that are material from the point of view of accountability.

4.2. The Processor ensures that the persons authorised to process personal data have committed themselves to confidentiality.

4.3. The Processor is not entitled to process the entrusted personal data for its own, marketing, training or analytical purposes, with the exception of processing necessary to ensure the security, accountability and correct functioning of the System, in accordance with the Agreement and the Terms.

4.4. The development and improvement of the System's features may take place solely:

• (a) on the basis of data that is aggregated or permanently anonymised in a manner that makes it impossible to identify natural persons; or
• (b) on the basis of data whose use for training models or for tests has been expressly agreed in writing between the Parties.

Under no circumstances will the Processor use the Controller's unaltered personal data to train external AI models or make it available to third parties without the Controller's prior consent.

5. Security measures

5.1. The Processor applies security measures appropriate to the risk connected with the processing of personal data, in particular:

• (a) encryption of data in transit (TLS) and, where justified, encryption of data at rest;
• (b) access control based on role profiles and authorisation;
• (c) backup systems and a data restoration policy;
• (d) security monitoring and the logging of access and events;
• (e) procedures for detecting and responding to security incidents;
• (f) policies concerning passwords, multi-factor authentication for administrative access and access management.

5.2. The Processor takes action to regularly test, assess and evaluate the effectiveness of the protective measures applied.

6. Sub-processors

6.1. The Controller grants the Processor general consent to use third parties as further processors (sub-processors) in the categories indicated in point 6.2.

6.2. Sub-processors may be used in particular in the area of:

• (a) hosting and IT infrastructure,
• (b) analytical tools and services connected with data processing (including tools supporting AI),
• (c) communication and mailing services,
• (d) payment, settlement and accounting systems,
• (e) technical support and security services.

6.3. The Processor ensures that an agreement will be concluded with each sub-processor setting out the sub-processor's obligations in the area of personal data protection, corresponding at least to the Processor's obligations under this Agreement and under the GDPR.

6.4. The Processor maintains an up-to-date list of sub-processors and may make it available to the Controller on the Website or on request. The Processor will notify the Controller of its intention to entrust processing to a new sub-processor sufficiently in advance to allow the Controller to object on justified grounds connected with data protection. In the absence of a justified objection, the Processor may entrust processing to the sub-processor.

7. Transfers of data outside the EEA

7.1. Where personal data is transferred outside the European Economic Area (EEA), the Processor applies appropriate legal safeguards, in particular standard contractual clauses approved by the European Commission (SCC) or other mechanisms compliant with the GDPR.

7.2. The Processor will make information about the safeguarding mechanisms adopted available to the Controller on request.

8. Personal data breaches

8.1. The Processor undertakes to inform the Controller of an identified personal data breach without undue delay, but no later than within 72 hours of its detection, unless providing the information later is justified by the circumstances.

8.2. The notification contains, insofar as available, a description of the nature of the breach, the categories and number of persons and records of data concerned, the likely consequences of the breach and the measures taken or proposed in order to address the breach.

8.3. The Processor cooperates with the Controller in order to limit the effects of the breach and to fulfil the obligations arising from the GDPR, including as regards notifying the breach to the supervisory authority and communicating with the data subjects (insofar as this is required).

9. Support in exercising data subjects' rights and the Controller's obligations

9.1. The Processor, insofar as technically and organisationally possible, supports the Controller in handling the requests of data subjects (e.g. access, rectification, erasure, restriction of processing, data portability), providing the Controller with the information necessary to meet those requests.

9.2. The Processor supports the Controller in fulfilling the obligations arising from Articles 32–36 of the GDPR, in particular as regards: data protection impact assessments (DPIA), consultation with the supervisory authority and the implementation of security measures in accordance with Article 32 of the GDPR.

10. End of processing and deletion of data

10.1. After the provision of the Services ends or at the Controller's request, the Processor, at the Controller's choice:

• (a) returns to the Controller all the personal data entrusted to it, in a format agreed by the Parties; or
• (b) deletes the personal data from the systems of the Processor and of the sub-processors, including any existing copies, in accordance with security procedures.

10.2. The obligation referred to above does not concern data whose further retention is required by the applicable law; in such a case the Processor indicates the categories of that data and the retention period.

11. Audits and inspections

11.1. The Controller is entitled to verify that the processing of data complies with the Agreement and the GDPR, in a manner that does not disrupt the Processor's activity. Verification may consist in: (i) providing the results of audits carried out by an independent auditor, (ii) presenting reports of external security certifications, or (iii) carrying out an on-site audit after the scope, date and conditions have been agreed in advance.

11.2. Audits may not lead to the disclosure of the Processor's business secrets, source code, or information relating to the Processor's other clients.

11.3. Audits may be carried out no more often than once a year, unless a material breach occurs or the supervisory authority requires a different course of action; in such a case the Parties will agree a reasonable schedule and scope for the inspection.

12. Limitation of liability

12.1. The Parties declare that responsibility for the lawfulness of the processing of data rests essentially with the Controller. At the same time, the Processor is liable for breaches resulting from a breach of the provisions of this Agreement or of the obligations arising from the GDPR in relation to the scope of its activity as Processor.

13. Duration of the Agreement

13.1. The Agreement is in force for the duration of the main agreement arising from the Terms and for the time necessary to perform the obligations arising from this Agreement, including until the procedures connected with the deletion or return of data have been completed and until the retention periods required by law have ended.

14. Final provisions

14.1. In matters not regulated by this Agreement, the provisions of the Terms and the provisions of the GDPR and other applicable law apply.

14.2. In the event of a conflict between the provisions of this Agreement and the Terms, the provisions of this Agreement take precedence as regards the protection of personal data.

14.3. The Agreement is governed by the law of the Republic of Poland.

14.4. The Parties will endeavour to settle any disputes arising from this Agreement amicably; failing agreement, the competent court will be the court having jurisdiction over the registered office of the Processor, unless the Parties decide otherwise.

List of example categories of sub-processors / data recipients – informational appendix

(Note: this list is informational in nature and may change; the current list may be published on the Website or provided to the Controller on request.)

• Providers of hosting and infrastructure services (e.g. cloud providers),
• Providers of analytical and telemetry tools,
• Providers of communication and mailing solutions,
• Operators of payment and settlement systems,
• Providers of IT security services and technical support,
• Accounting offices, law firms and providers of audit services (where this is necessary for the Processor's operations),
• Other sub-processors carrying out activities necessary for the provision of the Services.

Closing statement

This Personal Data Processing Agreement forms an integral part of the Terms and is in force from the moment the Controller accepts the Terms and begins using the Services.