Data Processing Addendum

This addendum forms part of the Agreement and governs Hermitage’s handling of Subscriber Data. Where it conflicts with the Agreement on data handling, this addendum controls.

Roles. Subscriber determines why and how Subscriber Data is processed. Hermitage processes it only on Subscriber’s behalf, as a service provider.

Ownership and use. Subscriber owns Subscriber Data. Hermitage processes it only to provide, secure and support the Platform and as Subscriber directs. Hermitage does not sell or share Subscriber Data, does not use it to train artificial intelligence models, and uses AI providers only under terms that prohibit them from training on it.

Confidentiality. Hermitage limits access to Subscriber Data to personnel and contractors who need it to provide the Platform and who are bound by confidentiality obligations.

Security. Hermitage maintains administrative, technical and physical safeguards appropriate to the sensitivity of Subscriber Data, as described in its security overview, and will not materially reduce them during the subscription term.

Subprocessors. Subscriber authorizes the subprocessors Hermitage lists publicly. Hermitage will give at least 30 days’ notice before adding or replacing one. If Subscriber reasonably objects, Subscriber may end the subscription and receive a refund of prepaid fees for the unused term. Hermitage remains responsible for its subprocessors’ performance.

Security incidents. Hermitage will notify Subscriber without undue delay, and in any event within 72 hours, after confirming a security incident affecting Subscriber Data. The notice will describe what is known of the incident and the steps taken, and Hermitage will cooperate reasonably with Subscriber’s response.

Requests and legal process. Hermitage will reasonably assist Subscriber in responding to requests from individuals about their data. If Hermitage receives a subpoena or other legal demand for Subscriber Data, it will notify Subscriber before responding unless the law prohibits it.

Retention and deletion. Hermitage keeps Subscriber Data for 90 days after the subscription ends. If Subscriber resubscribes within those 90 days, it resumes with its data intact. Hermitage then deletes Subscriber Data, except copies in backups, which remain protected under this addendum until they expire in the ordinary backup cycle.

Information. Once a year, on request, Hermitage will answer Subscriber’s reasonable written security questionnaire.