This Data Processing Addendum (“DPA”) supplements Granola’s standard terms, any related Enterprise Order Form, and/or Terms of Use (the “Agreement”) entered into by and between the customer identified in the Agreement (“Customer”) and Granola. This DPA incorporates the terms of the Agreement, and any terms not defined in this DPA shall have the meaning set forth in the Agreement.  

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1. Definitions

  1. “Authorized Subprocessor” means a third-party who has a need to know or otherwise access Customer’s Personal Data to enable Granola to perform its obligations under this DPA or the Agreement, and who is either (1) listed in Exhibit B or (2) subsequently authorized under Section 4.2 of this DPA.
  2. “Privacy Laws” means any applicable laws and regulations in any relevant jurisdiction relating to the use or processing of Personal Data including, each to the extent applicable: (i) the General Data Protection Regulation (Regulation (EU) 2016/679) (“EU GDPR”) and the EU GDPR as it forms part of the law of England and Wales by virtue of section 3 of the European Union (Withdrawal) Act 2018 (“UK GDPR”) (together, collectively, the “GDPR”), (ii) the Swiss Federal Act on Data Protection; (iii) the UK Data Protection Act 2018, (iv) the Privacy and Electronic Communications (EC Directive) Regulations 2003; (vv) U.S. state comprehensive privacy laws, such as the California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (“CCPA”), in each case, as updated, amended or replaced from time to time. The terms, “controller,” “Personal Data Breach”, “processing”, “processor,” “sell”, “share”, and “supervisory authority” shall have the meanings set forth for such or equivalent terms under Privacy Laws.   
  3. “Data Privacy Framework” means, as applicable, EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework, and/or the Swiss-U.S. Data Privacy Framework.  
  4. “Data Subject” means a natural person whose Personal Data is protected by Privacy Laws. For the avoidance of doubt, “Data Subject” includes the term “Consumer” under Privacy Laws.
  5. “Data Subject Request” means a request from a Data Subject to exercise their rights over Personal Data afforded pursuant to Privacy Laws.
  6. “ex-EEA Transfer” means the transfer of Personal Data subject to the GDPR from the European Economic Area (“EEA”), to a country where the transfer is not governed by an adequacy decision made by the European Commission in accordance with the relevant provisions of the GDPR. 
  7. “ex-UK Transfer” means the transfer of Personal Data subject to Chapter V of the UK GDPR from outside the United Kingdom (“UK”) where such transfer is not governed by an adequacy decision made by the Secretary of State in accordance with the relevant provisions of the UK GDPR and the Data Protection Act 2018. 
  8. “Personal Data” means any information provided to Granola by or on behalf of Customer in connection with the Services that relates to an identified or identifiable Data Subject and constitutes “personal data,” “personal information,” or equivalent term under Privacy Laws.  
  9. “Standard Contractual Clauses” means, as applicable, (i) with respect to ex-EEA Transfers, the means standard contractual clauses approved by the European Commission in Commission Decision 2021/914 dated 4 June 2021, for transfers of personal data to countries not otherwise recognized as offering an adequate level of protection for personal data by the European Commission (as amended and updated from time to time), as modified by Section 9 of this DPA. (“EU SCCs”) and, (ii) with respect to ex-UK Transfers, the EU SCCs amended by the UK Addendum (“UK SCCs”)
  10. “UK Addendum” means the template International Data Transfer Addendum issued by the Information Commissioner and laid before Parliament in accordance with s119A of the Data Protection Act 2018 on 2 February 2022 (as may be amended from time to time), as completed by Exhibit C. International Data Transfer Addendum to the EU Commission Standard Contractual Clauses issued by the Information Commissioner under S119A(1) Data Protection Act of 2018

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2. Role of the Parties; Description of Processing

  1. Except as expressly set forth in this DPA or the Agreement, with respect to Personal Data, Customer is the Controller and Granola is a Processor, or to the extent Customer is a Processor to a third-party Controller, Granola is a subprocessor. 
  2. Granola shall process Personal Data only (i) for purposes set forth in the Agreement, (ii) in a manner consistent with the documented instructions provided by Customer, which shall include the Agreement and this DPA, and (iii) as required by Privacy Laws or a supervisory authority; in such case, Granola shall inform Customer of that legal requirement before processing to the extent legally permitted. The subject matter, nature, purpose, and duration of this processing, as well as the types of Personal Data collected and categories of Data Subjects involved, are described in Exhibit A to this DPA. Granola shall immediately notify Customer if an instruction, in Granola’s opinion, infringes the Privacy Laws or supervisory authority.
  3. Granola shall not: (i) sell or share Personal Data; (ii) retain, use, or disclose Personal Data outside of Granola’s direct business relationship with Customer or for any purpose other than for a business purpose under the CCPA on behalf of Customer or as necessary to perform the Services for Customer pursuant to the Agreement, except as otherwise permitted in Agreement or by Privacy Laws; and (iii) combine Personal Data received from, or on behalf of, Customer with Personal Data that it receives from, or on behalf of, another party or person, except as necessary to provide the Services or as otherwise instructed by Customer. Granola shall immediately notify Customer if an instruction, in Granola’s opinion, infringes Privacy Laws or instruction of a supervisory authority.
  4. Customer shall, in its use of the Services, at all times process Personal Data, and provide instructions for the processing of Personal Data, in compliance with Privacy Laws. Customer shall ensure that the processing of Personal Data in accordance with Customer’s instructions will not cause Granola to be in breach of the Privacy Laws. Customer is solely responsible for the accuracy, quality, and legality of (i) the Personal Data provided to Granola by or on behalf of Customer, (ii) the means by which Customer acquired any such Personal Data, and (iii) the instructions it provides to Granola regarding the processing of such Personal Data. Customer shall not provide or make available to Granola any Personal Data in violation of the Agreement or otherwise inappropriate for the nature of the Services, and shall indemnify Granola from all claims and losses in connection therewith. 

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3. Confidentiality

Granola shall ensure that any person it authorizes to process Personal Data has agreed to protect Personal Data in accordance with Granola’s confidentiality obligations in the Agreement. Customer agrees that Granola may disclose Personal Data to its advisers, auditors or other third parties as reasonably required in connection with the performance of its obligations under this DPA, the Agreement, or the provision of Services to Customer.  

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4. Authorized Subprocessors

  1. Customer acknowledges and agrees that Granola may (1) engage its Affiliates and the Authorized Subprocessors listed in Exhibit B to this DPA to access and process Personal Data in connection with the Services and (2) from time to time engage additional third parties for the purpose of providing the Services, including without limitation the processing of Personal Data. By way of this DPA, Customer provides general written authorization to Granola to engage subprocessors as necessary to perform the Services.
  2. A list of Granola’s current Authorized Subprocessors can be found at trust.granola.ai/subprocessors (the “List”).  Such List may be updated by Granola from time to time.  Granola may provide a mechanism to subscribe to notifications of new Authorized Subprocessors and Customer agrees to subscribe to such notifications where available.  At least ten (10) days before enabling any third party other than existing Authorized Subprocessors to access or participate in the processing of Personal Data, Granola will add such third party to the List and notify Customer via email. Customer may object to such an engagement by informing Granola within ten (10) days of receipt of the aforementioned notice to Customer, provided such objection is in writing and based on reasonable grounds relating to data protection. Customer acknowledges that certain subprocessors are essential to providing the Services and that objecting to the use of a subprocessor may prevent Granola from offering the Services to Customer.
  3. If Customer reasonably objects to an engagement in accordance with Section 4.2, and Granola cannot provide a commercially reasonable alternative within a reasonable period of time, Customer may discontinue the use of the affected Service by providing written notice to Granola.  Discontinuation shall not relieve Customer of any fees owed to Granola under the Agreement. If Customer does not object to the engagement of a third party in accordance with Section 4.2 within ten (10) days of notice by Granola, that third party will be deemed an Authorized Subprocessor for the purposes of this DPA.
  4. Granola will enter into a written agreement with the Authorized Subprocessor imposing on the Authorized Subprocessor data protection obligations comparable to those imposed on Granola under this DPA with respect to the protection of Personal Data.  In case an Authorized Subprocessor fails to fulfill its data protection obligations under such written agreement with Granola, Granola will remain liable to Customer for the performance of the Authorized Subprocessor’s obligations under such agreement.
  5. If Customer and Granola have entered into Standard Contractual Clauses as described in Section 6 (Transfers of Personal Data), (i) the above authorizations will constitute Customer’s prior written consent to the subcontracting by Granola of the processing of Personal Data if such consent is required under the Standard Contractual Clauses, and (ii) the parties agree that the copies of the agreements with Authorized Subprocessors that must be provided by Granola to Customer pursuant to Clause 9(c) of the EU SCCs may have commercial information, or information unrelated to the Standard Contractual Clauses or their equivalent, removed by Granola beforehand, and that such copies will be provided by Granola only upon request by Customer.

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5. Security of Personal Data

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, Granola shall maintain appropriate technical and organizational measures to ensure a level of security appropriate to the risk of processing Personal Data, as described on Granola’s Trust Center, available at: trust.granola.ai (“Granola Security Page”). 

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6. Transfers of Personal Data

  1. The parties agree that Granola may transfer Personal Data processed under this DPA outside the EEA, the UK, or Switzerland as necessary to provide the Services. Customer acknowledges that Granola’s primary processing operations take place in the United States, and that the transfer of Customer’s Personal Data to the United States is necessary for the provision of the Services to Customer. If Granola transfers Personal Data protected under this DPA to a jurisdiction for which the European Commission has not issued an adequacy decision, Granola will ensure that appropriate safeguards have been implemented for the transfer of Personal Data in accordance with Privacy Laws.
  2. ex-EEA Transfers. The parties agree that ex-EEA Transfers will be made (i) pursuant to the Data Privacy Framework, or (ii) if the Data Privacy Framework does not apply or ceases to be available, pursuant to the EU SCCs, which are deemed entered into (and incorporated into this DPA by this reference) and completed as follows:
    1. Module One (Controller to Controller) of the EU SCCs apply when Granola is processing Personal Data as a controller pursuant to Section 11 of this DPA.  
    2. Module Two (Controller to Processor) of the EU SCCs apply when Customer is a controller and Granola is processing Personal Data for Customer as a processor pursuant to Section 2 of this DPA.
    3. Module Three (Processor to Subprocessor) of the EU SCCs apply when Customer is a processor and Granola is processing Personal Data on behalf of Customer as a subprocessor.
  3. For each module, where applicable the following applies: 
    1. The optional docking clause in Clause 7 does not apply. 
    2. In Clause 9, Option 2 (general written authorization) applies, and the minimum time period for prior notice of subprocessor changes shall be as set forth in Section 4.2 of this DPA; 
    3. In Clause 11, the optional language does not apply; 
    4. All square brackets in Clause 13 are hereby removed; 
    5. In Clause 17 (Option 1), the EU SCCs will be governed by the law of the Republic of Ireland;
    6. In Clause 18(b), disputes will be resolved before the courts of the Republic of Ireland; 
    7. Exhibit B to this DPA contains the information required in Annex I and Annex III of the EU SCCs; 
    8. The Granola Security Page contains the information required in Annex II of the EU SCCs; and 
    9. By entering into this DPA, the parties are deemed to have signed the EU SCCs incorporated herein, including their Annexes. 
  4. ex-UK Transfers. The parties agree that ex-UK Transfers will be made (i) pursuant to the Data Privacy Framework, or (ii) if the Data Privacy Framework does not apply or ceases to be available, pursuant to the UK SCCs, which are deemed entered into and incorporated into this DPA by reference, as completed by Exhibit C. 
  5. Transfers from Switzerland. The parties agree that transfers from Switzerland will be made (i) pursuant to the Data Privacy Framework, or (ii) if the Data Privacy Framework does not apply or ceases to be available, pursuant to the EU SCCs with the following modifications: 
    1. The terms “General Data Protection Regulation” or “Regulation (EU) 2016/679” as utilized in the EU SCCs shall be interpreted to include the Federal Act on Data Protection of 19 June 1992 (“FADP,” and as revised as of 25 September 2020, the “Revised FADP”) with respect to data transfers subject to the FADP.
    2. Clause 13 of the EU SCCs is modified to provide that the Federal Data Protection and Information Commissioner (“FDPIC”) of Switzerland shall have authority over data transfers governed by the FADP and the appropriate EU supervisory authority shall have authority over data transfers governed by the GDPR. Subject to the foregoing, all other requirements of Clause 13 shall be observed. 
    3. The term “EU Member State” as utilized in the EU SCCs shall not be interpreted in such a way as to exclude Data Subjects in Switzerland from exercising their rights in their place of habitual residence in accordance with Clause 18(c) of the EU SCCs. 
  6. Supplementary Measures. In respect of any ex-EEA Transfer or ex-UK Transfer made pursuant to the Standard Contractual Clauses, the following supplementary measures shall apply:
    1. As of the date of this DPA, the Granola has not received any formal legal requests from any government intelligence or security service/agencies in the country to which the Personal Data is being exported, for access to (or for copies of) Customer’s Personal Data (“Government Agency Requests”).
    2. If, after the date of this DPA, the Granola receives any Government Agency Requests, Granola shall attempt to redirect the law enforcement or government agency to request that data directly from Customer. As part of this effort, Granola may provide Customer’s basic contact information to the government agency. If compelled to disclose Customer’s Personal Data to a law enforcement or government agency, Granola shall give Customer reasonable notice of the demand and cooperate to allow Customer to seek a protective order or other appropriate remedy unless Granola is legally prohibited from doing so. Granola shall not voluntarily disclose Personal Data to any law enforcement or government agency. Customer and Granola shall (as soon as reasonably practicable) discuss and determine whether all or any transfers of Personal Data pursuant to this DPA should be suspended in the light of the such Government Agency Requests;
    3. Customer and Granola will confer regularly, as needed, to consider whether: (i) the protection afforded by the laws of the country of the Granola to data subjects whose Personal Data is being transferred is sufficient to provide broadly equivalent protection to that afforded in the EEA or the UK, whichever the case may be; (ii) additional measures are reasonably necessary to enable the transfer to be compliant with the Privacy Laws; and (iii) it is still appropriate for Personal Data to be transferred to the relevant Granola, taking into account all relevant information available to the parties, together with guidance provided by the supervisory authorities.
    4. If Privacy Laws require the Customer to execute the Standard Contractual Clauses applicable to a particular transfer of Personal Data to a Granola as a separate agreement, the Granola shall, on request of the Customer, promptly execute such Standard Contractual Clauses incorporating such amendments as may reasonably be required by the Customer to reflect the applicable appendices and annexes, the details of the transfer and the requirements of the relevant Privacy Laws.
    5. If either (i) any of the means of legitimizing transfers of Personal Data outside of the EEA or UK set forth in this DPA cease to be valid or (ii) any supervisory authority requires transfers of Personal Data pursuant to those means to be suspended, then Granola may by notice to the Customer, with effect from the date set out in such notice, amend or put in place alternative arrangements in respect of such transfers, as required by Privacy Laws.

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7. Rights of Data Subjects

  1. Granola shall, to the extent permitted by Privacy Laws, notify Customer upon receipt of a Data Subject Request. If Granola receives a Data Subject Request in relation to Personal Data, Granola will advise the Data Subject to submit their request to Customer and Customer will be responsible for responding to such request, including, where necessary, by using the functionality of the Services. Customer is solely responsible for ensuring that Data Subject Requests communicated to Granola, and, if applicable, for ensuring that a record of consent to processing is maintained with respect to each Data Subject.
  2. Granola shall, at the request of Customer, and taking into account the nature of the processing applicable to any Data Subject Request, apply appropriate technical and organizational measures to assist Customer in complying with Customer’s obligation to respond to such Data Subject Request and/or in demonstrating such compliance, where possible, provided that (i) Customer is itself unable to respond without Granola’s assistance and (ii) Granola is able to do so in accordance with all applicable laws, rules, and regulations. Customer shall be responsible to the extent legally permitted for any costs and expenses arising from any such assistance by Granola.

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8. Actions and Access Requests; Audits

  1. Granola shall, taking into account the nature of the processing and the information available to Granola, provide Customer with reasonable cooperation and assistance where necessary for Customer to comply with its obligations under the Privacy Laws to conduct a data protection impact assessment and/or to demonstrate such compliance, provided that Customer does not otherwise have access to the relevant information. Customer shall be responsible to the extent legally permitted for any costs and expenses arising from any such assistance by Granola.
  2. Granola shall, taking into account the nature of the processing and the information available to Granola, provide Customer with reasonable cooperation and assistance with respect to Customer’s cooperation and/or prior consultation with any Supervisory Authority or regulatory agency, where necessary and where required by the Privacy Laws. Customer shall be responsible to the extent legally permitted for any costs and expenses arising from any such assistance by Granola.
  3. Granola shall maintain records sufficient to demonstrate its compliance with its obligations under this DPA. Upon Customer’s written request at reasonable intervals, and subject to reasonable confidentiality controls, Granola shall, either (i) make available for Customer’s review copies of certifications or reports demonstrating Granola’s compliance with prevailing data security standards applicable to the processing of Customer’s Personal Data, or (ii) if the provision of reports or certifications pursuant to (i) is not reasonably sufficient under Privacy Laws, allow Customer’s independent third party representative to conduct an audit or inspection of Granola’s data security infrastructure and procedures that is sufficient to demonstrate Granola’s compliance with its obligations under Privacy Laws, provided that (a) Customer provides reasonable prior written notice of any such request for an audit and such inspection shall not be unreasonably disruptive to Granola’s business; (b) such audit shall only be performed during business hours and occur no more than once per calendar year; and (c) such audit shall be restricted to data relevant to Customer. Customer shall be responsible for the costs of any such audits or inspections, including without limitation a reimbursement to Granola for any time expended for on-site audits.  If Customer and Granola have entered into Standard Contractual Clauses as described in Section 6 (Transfers of Personal Data), the parties agree that the audits described in Clause 8.9 of the EU SCCs shall be carried out in accordance with this Section 8.3. 

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9. Personal Data Breach

  1. In the event of a Personal Data Breach, Granola shall, without undue delay, inform Customer of the Personal Data Breach and take such steps as Granola in its sole discretion deems necessary and reasonable to remediate such violation (to the extent that remediation is within Granola’s reasonable control).
  2. In the event of a Personal Data Breach, Granola shall, taking into account the nature of the processing and the information available to Granola, provide Customer with reasonable cooperation and assistance necessary for Customer to comply with its obligations under the Privacy Laws with respect to notifying (i) the relevant Supervisory Authority or regulatory agency and (ii) Data Subjects affected by such Personal Data Breach without undue delay.
  3. The obligations described in Sections 9.1 and 9.2 shall not apply in the event that a Personal Data Breach results from the actions or omissions of Customer. Granola’s obligation to report or respond to a Personal Data Breach under Sections 9.1 and 9.2 will not be construed as an acknowledgement by Granola of any fault or liability with respect to the Personal Data Breach.

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10. Return or Destruction of Personal Data

Upon the termination or expiration of the Agreement, at Customer’s choice, Granola shall return or delete Personal Data, unless further storage of such Personal Data is required or authorized by applicable law. If return or destruction is impracticable or prohibited by law, rule or regulation, Granola shall take measures to block such Personal Data from any further processing (except to the extent necessary for its continued hosting or processing required by law, rule or regulation) and shall continue to appropriately protect the Personal Data remaining in its possession, custody, or control. If Customer and Granola have entered into Standard Contractual Clauses as described in Section 6 (Transfers of Personal Data), the parties agree that the certification of deletion of Personal Data that is described in Clause 8.1(d) and Clause 8.5 of the EU SCCs (as applicable) shall be provided by Granola to Customer only upon Customer’s request.

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11. Granola’s Role as a Controller

The parties acknowledge and agree that Granola may process Business Contact Data and Usage Data (as such terms are defined in the Agreement), as an independent controller, not a joint controller with Customer. Granola will process Business Contact Data and Usage Data as a controller (i) to manage the relationship with Customer; (ii) to carry out Granola’s core business operations, such as accounting, audits, tax preparation and filing and compliance purposes; (iii) to monitor, investigate, prevent and detect fraud, security incidents and other misuse of the Services, and to prevent harm to Customer; (iv) for identity verification purposes; (v) to comply with legal or regulatory obligations applicable to the processing and retention of Personal Data to which Granola is subject; and (vi) as otherwise permitted under Privacy Laws and in accordance with this DPA and the Agreement. Granola may also process Usage Data as a controller to provide, optimize, and maintain the Services, to the extent permitted by Privacy Laws. Any processing by Granola as a controller shall be in accordance with Granola’s privacy policy set forth at https://www.granola.ai/docs/policies/privacy/pp

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12. Conflict

In the event of any conflict or inconsistency among the following documents, the order of precedence will be: (1) the applicable terms in the Standard Contractual Clauses; (2) the terms of this DPA; (3) the Agreement; and (4) Granola’s privacy policy. Any claims brought in connection with this DPA will be subject to the terms and conditions, including, but not limited to, the exclusions and limitations set forth in the Agreement.

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Exhibit A

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Details of Processing

Nature and Purpose of Processing:   Granola will process Personal Data as necessary to provide the Services under the Agreement, for the purposes specified in the Agreement and this DPA, and in accordance with Customer’s instructions as set forth in this DPA. The nature of processing includes, without limitation: 
  • Receiving data, including collection, accessing, retrieval, recording, and data entry
  • Holding data, including storage, organization and structuring
  • Using data, including analysis, consultation, testing, 
  • Updating data, including correcting, adaptation, alteration, alignment and combination
  • Protecting data, including restricting, encrypting, and security testing
  • Sharing data, including disclosure, dissemination, allowing access or otherwise making available 
  • Returning data to the Customer or data subject
  • Erasing data, including destruction and deletion
Duration of Processing: Granola will process Personal Data as long as required to provide the Services to Customer or as otherwise set forth in the Agreement.  Categories of Data Subjects: Customer end-users/customers, Customer employees, and any other Data Subject authorized by Customer.  Categories of Personal Data: Granola processes Personal Data contained in Business Contact Data, Usage Data, and Customer Data provided to or otherwise collected by Granola in order to provide the Services or as otherwise set forth in the Agreement, including without limitation, any audio or transcript captured by Customer using the Services.  Sensitive Data or Special Categories of Data: None, except as provided at the sole discretion and responsibility of Customer in accordance with the Agreement.

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Exhibit B

The following includes the information required by Annex I and Annex III of the EU SCCs, and Table 1, Annex 1A, and Annex 1B of the UK Addendum. 
  1. The Parties
Data exporter(s): Customer Contact details: As designated by Customer in the applicable Order Form in connection with the Agreement.  Signature and date: By entering into the Agreement, Customer is deemed to have signed these Standard Contractual Clauses incorporated herein, as of the Effective Date of the Agreement. Role (controller/processor): The Customer’s role is set forth in Section 2 of this Addendum. Data importer(s): Granola Address: 1151 Walker Road, Suite 417, Dover, Delaware 19904 Contact details:  As designated by Customer in the applicable Order Form in connection with the Agreement. Signature and date: By entering into the Agreement, Granola is deemed to have signed these Standard Contractual Clauses incorporated herein, as of the Effective Date of the Agreement. Role (controller/processor): The Granola’s role is set forth in Section 2 of this Addendum.
  1. Description of the Transfer
Data Processing ElementDescription
Data SubjectsAs described in Exhibit A of the DPA
Categories of Personal DataAs described in Exhibit A of the DPA
Special Category Personal Data (if applicable)As described in Exhibit A of the DPA
Nature of the ProcessingAs described in Exhibit A of the DPA
Purposes of ProcessingAs described in Exhibit A of the DPA
Duration of Processing and Retention (or the criteria to determine such period)As described in Exhibit A of the DPA
Frequency of the transferAs necessary to provide perform all obligations and rights with respect to Personal Data as provided in the Agreement or DPA
Recipients of Personal Data Transferred to the Data ImporterGranola’s list of Subprocessors can be found at: trust.granola.ai/subprocessors.
  1. Competent Supervisory Authority
The supervisory authority shall be the supervisory authority of the data exporter, as determined in accordance with Clause 13 of the EU SCCs. The supervisory authority for the purposes of the UK Addendum shall be the UK Information Commissioner’s Officer.

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Exhibit C

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UK Addendum: International Data Transfer Addendum to the EU Commission Standard Contractual Clauses

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Part 1: Tables

Table 1: Parties
FieldDetails
Start DateThis UK Addendum shall have the same effective date as the DPA
The PartiesExporterImporter
Parties’ DetailsCustomerGranola
Key ContactSee Exhibit B of this DPASee Exhibit B of this DPA
Table 2: Selected SCCs, Modules and Selected Clauses
FieldDetails
EU SCCsThe Version of the Approved EU SCCs which this UK Addendum is appended to as defined in the DPA and completed by Section 6.2 and 6.3 of the DPA.
Table 3: Appendix Information
AnnexDetails
Annex 1A: List of PartiesAs per Table 1 above
Annex 2B: Description of TransferSee Exhibit B of this DPA
Annex II: Technical and organisational measures including technical and organisational measures to ensure the security of the data:See the Granola Security Page
Annex III: List of Sub processors (Modules 2 and 3 only):See Exhibit B of this DPA
Table 4: Ending this UK Addendum when the Approved UK Addendum Changes
FieldSelection
Ending this UK Addendum when the Approved UK Addendum changes☒ Importer ☒ Exporter ☐ Neither Party

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Part 2: Mandatory Clauses

The Mandatory Clauses of the UK Addendum are incorporated herein by reference.