Data Protection Addendum

This Data Protection Addendum ("Addendum"), dated May 30, 2026, and effective as of the Addendum Effective Date (as defined below), forms part of the Terms of Service ("Terms") between (i) Enveu and (ii) Clients and Customers of Enveu, each being a "Party" and together the "Parties". The Parties hereby agree that the terms and conditions set out below shall be added as an Addendum to the Terms, and references in this Addendum to the Terms are to the Terms as amended by, and including, this Addendum.

1. Definitions

1.1 In this Addendum, the following terms shall have the meanings set out below and cognate terms shall be construed accordingly:

• (a) "Addendum Effective Date" has the meaning given to it in Section 2;
• (b) "Affiliate" means an entity that owns or controls, is owned or controlled by, or is under common control or ownership with either Client or Enveu (as the context allows), where control is defined as the possession, directly or indirectly, of the power to direct or cause the direction of the management and policies of an entity, whether through ownership of voting securities, by contract or otherwise;
• (c) "Client Personal Data" means any Personal Data Processed by Enveu (i) on behalf of Client (including any Client Affiliate), or (ii) otherwise Processed by Enveu, in each case pursuant to or in connection with instructions given by Client in writing, consistent with the Terms;
• (d) "Data Protection Laws" means all applicable privacy and data protection laws and regulations governing the Processing of Personal Data under this Addendum, including but not limited to the Digital Personal Data Protection Act, 2023 (DPDP Act) of India and, where applicable, the General Data Protection Regulation (GDPR);
• (e) "Services" means the services to be supplied by Enveu to Client or Client Affiliates pursuant to the Terms.

1.2 The terms "Controller", "Data Subject", "Personal Data", "Personal Data Breach", "Process", "Processor" and "Supervisory Authority" have the same meanings as described in applicable Data Protection Laws and cognate terms shall be construed accordingly.

1.3 Capitalized terms not otherwise defined in this Addendum shall have the meanings ascribed to them in the Terms.

2. Formation of this Addendum

This Addendum is deemed agreed by the Parties, and comes into effect, on the "Addendum Effective Date", being the later of (i) the date that this Addendum is accepted by Client; and (ii) the date that this Addendum is accepted by Enveu.

3. Roles of the Parties

The Parties acknowledge and agree that with regard to the Processing of Client Personal Data, and as more fully described in Annex 1 hereto, Client acts as a Controller and Enveu acts as a Processor (as defined in Section 5.2.4 below). The Parties expressly agree that Client shall be solely responsible for ensuring timely communications to Client's Affiliates or the relevant Controller(s) who receive the Services, insofar as such communications may be required or useful in light of applicable Data Protection Laws to enable Client's Affiliates or the relevant Controller(s) to comply with such Laws.

4. Description of Personal Data Processing

In Annex 1 to this Addendum, the Parties have mutually set out their understanding of the details of the Processing of the Client Personal Data to be Processed by Enveu pursuant to this Addendum, as required by Article 28(3) of the GDPR. Either Party may make reasonable amendments to Annex 1 by written notice to the other Party and as reasonably necessary to meet those requirements. Annex 1 does not create any obligation or rights for any Party.

5. Data Processing Terms

5.1 Client shall comply with all applicable Data Protection Laws in connection with the performance of this Addendum. As between the Parties, Client shall be solely responsible for compliance with applicable Data Protection Laws regarding the collection of and transfer to Enveu of Client Personal Data. Client agrees not to provide Enveu with any data concerning a natural person's health, religion or any special categories of data as defined in Article 9 of the GDPR.

Client acknowledges and agrees that if Client chooses to integrate, use, or grant access to any third-party applications, tools, or services within the Enveu environment, or grants third-party personnel access to the end-use systems, Client is solely responsible for the security and compliance of such third-party tools or access. Enveu shall bear no liability for any Personal Data Breach, data loss, or system compromise resulting from the actions, omissions, or vulnerabilities of such third-party tools, services, or personnel authorized by the Client.

5.2 Enveu shall comply with all applicable Data Protection Laws in the Processing of Client Personal Data and Enveu shall:

5.2.1 process the Client Personal Data relating to the categories of Data Subjects for the purposes of the Terms and for the specific purposes set out in Annex 1, and otherwise solely on the documented instructions of Client, for the purposes of providing the Services and as otherwise necessary to perform its obligations under the Terms (including with regard to transfers of Client Personal Data to a third country or international organization); Enveu shall immediately inform Client if, in Enveu's opinion, an instruction infringes applicable Data Protection Laws;

5.2.2 ensure that persons authorized to process the Client Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;

5.2.3 implement and maintain the technical and organizational measures set out in the Terms and, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of Processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, implement any further appropriate technical and organizational measures necessary to ensure a level of security appropriate to the risk, as follows:

• (a) pseudonymization and encryption of Client Personal Data;
• (b) ensuring ongoing confidentiality, integrity, availability and resilience of processing systems and services that process Client Personal Data;
• (c) restoring availability and access to Client Personal Data in a timely manner in the event of a physical or technical incident; and
• (d) regularly testing, assessing and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing of the Client Personal Data.

Any amendment to such agreed measures that is necessitated by Client shall be dealt with via an agreed change-control process between Enveu and Client.

5.2.4 Client (on behalf of the relevant Controller(s), as applicable) hereby expressly and specifically authorizes Enveu to engage another Processor to Process the Client Personal Data ("Other Processor"), and specifically the Other Processors listed in Annex 2 hereto, subject to Enveu's:

• (a) notifying Client of any intended changes to its use of Other Processors listed in Annex 2 by emailing notice of the intended change to Client;
• (b) including data protection obligations in its contract with each Other Processor that are materially the same as those set out in this Addendum; and
• (c) remaining liable to the Client for any failure by each Other Processor to fulfill its obligations in relation to the Processing of the Client Personal Data.

In relation to any notice received under Section 5.2.4(a), the Client shall have a period of 30 (thirty) days from the date of the notice to inform Enveu in writing of any reasonable objection to the use of that Other Processor. The parties will then, for a period of no more than 30 (thirty) days from the date of the Client's objection, work together in good faith to attempt to find a commercially reasonable solution which avoids the use of the objected-to Other Processor. Where no such solution can be found, either Party may (notwithstanding anything to the contrary in the Terms) terminate the relevant Services immediately on written notice to the other Party, without damages, penalty or indemnification whatsoever.

5.2.5 to the extent legally permissible, promptly notify Client of any communication from a Data Subject regarding the Processing of Client Personal Data, or any other communication (including from a Supervisory Authority) relating to any obligation under the applicable Data Protection Laws, and, taking into account the nature of the Processing, assist Client (or the relevant Controller) by appropriate technical and organizational measures, insofar as possible, for the fulfillment of the obligation to respond to requests for exercising the data subject's rights laid down in Chapter III GDPR; Client agrees to pay Enveu for time and out-of-pocket expenses incurred in connection with the performance of its obligations under this Section 5.2.5;

5.2.6 upon Enveu becoming aware of a Personal Data Breach involving Client Personal Data, notify Client without undue delay, such notice to include all information reasonably required by Client (or the relevant Controller) to comply with its obligations under applicable Data Protection Laws;

5.2.7 to the extent required by applicable Data Protection Laws, provide reasonable assistance to Client, Client's Affiliates or the relevant Controller(s) with their obligations pursuant to Articles 32 to 36 of the GDPR, taking into account the nature of the Processing and information available to Enveu; Client agrees to pay Enveu for time and out-of-pocket expenses incurred in connection with any assistance provided in connection with Articles 35 and 36 of the GDPR;

5.2.8 cease Processing the Client Personal Data upon termination or expiry of the Terms and, at the option of Client, Client's Affiliates or the relevant Controller(s), either return or delete (including by ensuring such data is in non-readable format) all copies of the Client Personal Data Processed by Enveu, unless (and solely to the extent and for such period as) country law requires storage of the Personal Data. Notwithstanding the foregoing, Enveu may retain Personal Data to the extent required by applicable laws or regulatory obligations; any such retained Personal Data shall remain subject to the obligations of confidentiality set forth in the Terms; and

5.2.9 make available to Client all information necessary to demonstrate compliance with this Addendum and allow for and contribute to audits, including inspections, by Client or an auditor mandated by Client. For the purposes of demonstrating compliance under this Section 5.2.9, the Parties agree that once per year during the term of the Terms, Enveu will provide to Client, on reasonable notice, responses to cybersecurity and other assessments. Client agrees to pay Enveu for time and out-of-pocket expenses incurred in connection with such audits and assessments.

6. Transfers

Enveu shall notify Client in writing without undue delay if it can no longer comply with its obligations under the Privacy compliance, and in such a case Enveu will have the option of (i) promptly taking reasonable steps to remediate any non-compliance, or (ii) engaging in a good-faith dialogue with Client to determine a new data transfer mechanism to carry out the purposes of the Terms. Enveu acts as a Processor with respect to Personal Data received pursuant to a data transfer. In the event the Privacy Compliance is invalidated, Client and each Client Affiliate (as "data exporter") and Enveu (as "data importer"), with effect from the commencement of the relevant transfer, shall enter into the Controller-to-Processor SCCs (mutatis mutandis) in respect of any transfer (or onward transfer) from Client or Client Affiliate to Enveu, where such transfer would otherwise be prohibited by applicable Data Protection Laws. Appendix 1 to the Controller-to-Processor SCCs shall be deemed prepopulated with the relevant sections of Annex 1 to this Addendum, and the processing operations are deemed to be those described in the Terms. Appendix 2 shall be deemed prepopulated as follows: "Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood for the rights and freedoms of natural persons, Enveu shall implement appropriate technical and organizational measures as set forth in the Addendum."

7. Precedence

The provisions of this Addendum are supplemental to the provisions of the Terms. In the event of any inconsistency between the provisions of this Addendum and the provisions of the Terms, the provisions of this Addendum shall prevail.

8. Indemnity

To the extent permissible by law, Client shall indemnify and hold harmless Enveu against all (i) losses, (ii) third-party claims, (iii) administrative fines, and (iv) costs and expenses (including, without limitation, reasonable legal, investigatory and consultancy fees and expenses) reasonably incurred in relation to (i), (ii) or (iii), suffered by Enveu and that arise from any breach by Client of this Addendum or of its obligations under applicable Data Protection Laws, or from any Personal Data Breach caused by third-party tools, integrations, or personnel authorized by the Client to access the Services.

9. Severability

The Parties agree that, if any section or sub-section of this Addendum is held by any court or competent authority to be unlawful or unenforceable, it shall not invalidate or render unenforceable any other section of this Addendum.

10. Other Provisions

The organization ensures that the contract to process PII addresses the organization's role in providing assistance with the customer's obligations. The Agreement considers and follows:

• (a) Privacy by Design and by default;
• (b) Achieving Security of Processing;
• (c) Notification of breaches involving PII to a Supervisory Authority;
• (d) Notification of breaches involving PII to Customers and PII Principals;
• (e) Conducting Privacy Impact Assessments;
• (f) Assurance of assistance by the PII Processors if prior consultations with relevant PII protection authorities are needed;
• (g) Enveu shall inform the customer if, in its opinion, a processing instruction infringes applicable legislation or regulation;
• (h) The organization does not use PII processed under a contract for the purposes of Marketing and Advertising;
• (i) Coordinate with Clients to help audit the systems. The organization provides the customer with appropriate information so that it can demonstrate compliance with its obligations;
• (j) Enveu shall use Public Cloud and PIPL as sub-processors with security and privacy requirements fulfilled;
• (k) The organization shall comply with all statutory and regulatory requirements, ISO 27001:2013, ISO 27701:2019 and GDPR requirements;
• (l) The Data shall be deleted or de-identified after the processing is complete (after the selected retention period is complete);
• (m) Enveu shall inform clients 24 hours in advance in case of any legally binding requests for disclosure of PII;
• (n) For Access, Correction and/or Erasure of PII of Data Subjects, and for raising concerns or complaints related to PII, contact the Data Protection Officer (DPO) below.

Data Protection Officer
Name: Shalabh Agarwal
Email: legal@enveu.com