Last Updated: April 19, 2023

This Data Processing Addendum and its Annexes (the “DPA“) reflect
the agreement made by and between MegaGroup and Customer (as
such terms are defined below), together the “Parties“, with respect
to the Processing of Customer Personal Data (defined below) under
the applicable terms and conditions or other written or electronic
agreement referencing this DPA under which MegaGroup Processes
Customer Personal Data that is subject to Applicable Data Protection
Law (the “Agreement“). This DPA will be incorporated into the
Agreement in accordance with the terms of the Agreement. This DPA
amends the Agreement and is effective upon its incorporation into
the Agreement, as specified in the Agreement or order between
MegaGroup and Customer. Upon its incorporation into the
Agreement, this DPA will form an integral part of the Agreement
without the need for any additional signatures. Notwithstanding
anything to the contrary in the Agreement, if there is a conflict
between this DPA and the Agreement, this DPA will control.

1. DEFINITIONS. For the purposes of this DPA, the following

terms have the following meanings unless the context
otherwise requires. Other capitalized terms not defined herein
will have the same meaning as set forth in the Agreement.

(a) “Affiliate“ means an entity that owns or controls, is owned or

controlled by or is under common ownership or control with the
subject entity, where “control” means the power to direct the
management or affairs of an entity and “ownership” means the
beneficial ownership of fifty percent (50%) or more of the voting
securities or other equivalent voting interests of the subject entity;

(b) “Applicable Data Protection Law” means all applicable

legislation relating to data protection and privacy including, where
applicable, the European Data Protection Laws and the CCPA;

(c) “CCPA” means the California Consumer Privacy Act and

implementing regulations, as may be amended from time to time;

(d) “Controller” means the entity which determines the purposes

and means of the Processing of Personal Data, including a “business”
as defined by the CCPA;

(e) “Customer” means the entity that enters into the Agreement
with MegaGroup for use of or access to the Services;

(f) “Customer Personal Data” means the Personal Data described

in Annex I to this DPA, in respect of which the Customer is the
Controller;
(g) “Data Subject”, “Process”, “Processed” or
“Processing” shall each have the meaning as set out in the
European Data Protection Laws;

(h) “European Data Protection Laws” means the GDPR, the Data
Protection Act 2018 of the United Kingdom ("UK") and the Swiss
Federal Act on Data Protection, each as amended or replaced from
time to time;

(i) “EU Standard Contractual Clauses” means the Standard

Contractual Clauses approved with Commission Implementing
Decision (EU) 2021/914 of 4 June 2021 on standard contractual
clauses for the transfer of personal data to third countries pursuant
to Regulation (EU) 2016/679 of the European Parliament and of the
Council;

(j) “GDPR” means the European Union General Data Protection

Regulation (EU) 2016/679 of the European Parliament and of the
Council of 27 April 2016 on the protection of natural persons with
regard to the processing of personal data and on the free movement
of such data (“EU GDPR”) and the EU GDPR in such form as
incorporated into the laws of the UK “UK GDPR”), each as amended
or replaced from time to time;

(k) “Personal Data” means personal data or personal information

(as defined under the Applicable Data Protection Law) that is subject
to the Applicable Data Protection Law;

(l) “Personal Data Breach” means a breach of security leading to

the accidental or unlawful destruction, loss, alteration, unauthorized
disclosure of, or access to, Personal Data transmitted, stored or
otherwise processed;

(m) “Processor” means the entity which Processes Personal Data on

behalf of the Controller, including as applicable any “service
provider” as that term is defined by the CCPA;

(n) “Regulator” means the data protection supervisory authority

which has jurisdiction over the Processing of Personal Data;

(o) “Webinauts” means MegaGroup or any Affiliate of MegaGroup

that enters into an Agreement with Customer;

(p) “Services” means the services provided by MegaGroup to the

Customer under the Agreement;

(q) “Standard Contractual Clauses” means collectively the EU

Standard Contractual Clauses and the UK International Data Transfer
Agreement (as described in Section 6 (c) of this DPA); and
(r) “Sub-Processor” means (i) any Processor engaged by Data
Processor or (ii) a Data Processor’s Affiliate.

2. PROCESSING OF CUSTOMER PERSONAL DATA.

(a) The Parties acknowledge and agree that with regard to the
Processing of Customer Data, Customer is the Controller (the “Data
Controller”) and MegaGroup is a Processor (the “Data Processor”).
MegaGroup will Process Customer Data in accordance with
Customer’s instructions as outlined in this section and in Section 4
(Data Processor’s Obligations).

(b) MegaGroup will Process Customer Personal Data (i) in accordance

with the Agreement; (ii) at the Customer’s request when accessing or
using the Services; or (iii) to comply with other reasonable
instructions of the Data Controller (e.g., via email or support tickets)
that are consistent with the terms of this DPA (individually and
collectively, the “Purpose”). The types of Personal Data and
categories of Data Subjects Processed under this DPA, the subject-
matter, nature, purpose and duration of the Processing are further
specified in Annex I to this DPA. If Customer’s Affiliates have
purchased subscriptions to the Services directly with MegaGroup
under the Agreement, then this DPA amends the terms of the
Agreement with respect to those subscriptions, and each such
Affiliate shall be deemed to be the “Data Controller” for the purposes
of this DPA. Customer shall be responsible for coordinating all
communications with MegaGroup and Customer’s Affiliates under this
DPA and shall be entitled to make and receive any communication in
relation to the DPA, on behalf of itself and its Affiliates.

3. DATA CONTROLLER

(a) The Data Controller shall, in its use of the Services, Process
Customer Personal Data in accordance with the requirements of
Applicable Data Protection Law. Customer’s instructions for the
Processing of Customer Personal Data shall comply with Applicable
Data Protection Law. Customer shall have sole responsibility for the
accuracy, quality, and legality of Customer Personal Data and the
means by which Customer obtained Customer Personal Data.

(b) The Data Controller warrants that it has all necessary rights to
provide the Customer Personal Data to the Data Processor for the
Processing to be performed in relation to the Services. To the extent
required by Applicable Data Protection Law, the Data Controller is
responsible for ensuring that any necessary Data Subject consents to
this Processing are obtained, and for ensuring that a record of such
consents is maintained. Should such a consent be revoked by the
Data Subject, Data Controller is responsible for communicating the
fact of such revocation to the Data Processor, and Data Processor
remains responsible for implementing any Data Controller instruction
with respect to the further Processing of Customer Personal Data that
is consistent with the terms of this DPA.

4. DATA PROCESSOR’S OBLIGATIONS.

4.1 To the extent the Data Processor Processes Customer Personal

Data on behalf of the Data Controller, it shall:

(a) Process the Customer Personal Data only on documented

instructions from the Data Controller in such manner as, and to the
extent that, this is appropriate for the provision of the Services,
including with regard to transfers of Personal Data to third countries,
except as required to comply with applicable laws in the EEA, EEA
member states, the UK, or Switzerland, to which the Data Processor
is subject. In such a case, the Data Processor shall, to the extent
legally permitted by those laws, inform the Data Controller of that
legal obligation before Processing. The Data Processor shall
immediately inform the Data Controller if, in its opinion, an
instruction infringes the data protection laws of the EEA, EEA
member states, the UK, or Switzerland;

(b) ensure that all persons or parties authorized to Process the

Customer Personal Data have committed themselves to
confidentiality or are under an appropriate statutory obligation of
confidentiality;

(c) at all times have in place an appropriate written security policy

with respect to the Processing of Customer Personal Data, outlining
in any case the measures referenced in Section 5 below.

To the extent Webinauts' Processing of Customer Personal Data is

subject to the CCPA, MegaGroup shall not (1) retain, use, or disclose
Customer Personal Data other than as provided for in the Agreement,
as needed to perform the Services, to build or improve the quality of
the Services, to detect security incidents, to protect against
fraudulent or illegal activity, to retain Sub-Processors in compliance
with Section 7, or as otherwise permitted by the CCPA; or (2) sell (as
defined in the CCPA) Customer Personal Data.

5. SECURITY

(a) 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 Data Subjects, without prejudice to any
other security standards agreed upon by the Parties, the Data
Controller and Data Processor shall implement appropriate technical
and organizational measures for the protection of the security,
confidentiality and integrity of the Customer Personal Data
appropriate to the risk. These measures include the measures set
forth in Annex II attached hereto.

(b) The Data Processor will regularly monitor the measures as

implemented in accordance with this Section 5. The Data Processor
may update the security measures from time to time provided that
such updates do not result in a degradation of the overall security of
the Services.

(c)The parties will negotiate in good faith the cost, if any, to

implement material changes required by specific updated security
requirements set forth in the Applicable Data Protection Law or by
Regulators of competent jurisdictions.

(d) At the Data Controller's request, subject to the confidentiality

obligations set forth in the Agreement, the Data Processor shall
provide to the Data Controller information regarding the measures
taken pursuant to this Section 5 in order to ensure its compliance
with its obligations under this DPA. Such information may include
overviews of the Data Processor’s third-party audit reports or third-
party certifications (which may be redacted for security purposes).
The Data Controller may contact the Data Processor in accordance
with the “Notices” section of the Agreement to request an on-site
audit of the Data Processor’s procedures relevant to the protection of
Customer Personal Data, but only to the extent required under the
Applicable Data Protection Law. The Data Controller may conduct
such an audit not more than once annually, unless otherwise
required by Applicable Data Protection Law. The Data Controller shall
reimburse the Data Processor for any time spent on any such on-site
audit at the Data Processor’s then-current rates, which are available
upon request. The Data Controller shall provide at least thirty (30)
days' prior written notice of its request to undertake such on-site
audit, and the Data Controller and Data Processor shall, before the
commencement of any such audit, mutually agree upon the scope,
timing, the duration and the rate of reimbursement of such audit. (All
reimbursement rates shall be reasonable, taking into account the
resources expended by the Data Processor.) The Data Controller shall
promptly notify the Data Processor of any non-compliance discovered
during the course of such audit, and the Data Processor will use
commercially reasonable efforts to address any confirmed non-
compliance. The results of any audit performed hereunder shall be
deemed Webinauts’s Confidential Information. If the Standard
Contractual Clauses apply to this DPA, then the Data Controller
agrees to exercise its audit rights under the Standard Contractual
Clauses as described in this Section 5(d), and the Data Controller has
the right under the Standard Contractual Clauses to change its
instruction and agrees to do so in writing pursuant to the "Notices"
section of the Agreement.
 6. INTERNATIONAL TRANSFERS

(a) In connection with the performance of the Agreement, the Parties

hereby agree to be bound by the provisions of Module Two
(Controller to Processor Module) of the EU Standard Contractual
Clauses and all other sections of the EU Standard Contractual
Clauses having general application (hereinafter, “C2P SCCs”), which
are hereby incorporated into this DPA by reference, in order to
implement appropriate safeguards for transfers of Customer Personal
Data originating from the EEA and/or Switzerland to the United
States pursuant to European Data Protection Laws. The C2P SCCs
shall automatically terminate if the European Data Protection Board
or other competent authorities determine that EU Standard
Contractual Clauses are not applicable to the type of transfers of
Customer Personal Data hereunder. The Data Controller shall comply
with the exporter’s obligations in the EU Standard Contractual
Clauses, and the Data Processor shall comply with the importer’s
obligations in the EU Standard Contractual Clauses in respect of that
transferred Customer Personal Data. In furtherance of the foregoing,
the Parties agree that, for purposes of the C2P SCCs:

(i) each Party will notify the other Party in writing if it requires
adding the “docking clause” in Clause 7 of the C2P SCCs;

(ii) in Clause 9, Option 2 will apply, and the time period for prior
notice of sub-Processor changes will be as set forth in Section 7
(Subprocessing) of this DPA;

(iii) in Clause 11, the optional language will not apply;

(iv) in Clause 17 (Option 1), the 2021 Standard Contractual Clauses

will be governed by the laws of the Czech Republic.

(v) in Clause 18(b), disputes will be resolved before the courts of

Czech Republic;

(vi) Annex I of the C2P SCCs shall be deemed completed with the
information set out in Annex I to this DPA;

(vii) Annex II of the C2P SCCs shall be deemed completed with the
information set out in Annex II to this DPA.

(b) Insofar as the transfer of Customer Personal Data is subject to the

Swiss Federal Act on Data Protection, the following provisions apply:
(i) the Federal Data Protection and Information Commissioner (FDPIC)
will be the competent supervisory authority under Clause 13 of the
C2P SCCs; (ii) the Parties agree to abide by the EU GDPR standard in
relation to all Processing of Customer Personal Data that is governed
by the Swiss Federal Act on Data Protection; (iii) the term ‘Member
State’ in the C2P SCCs will not be interpreted in such a way as to
exclude Data Subjects in Switzerland from the possibility of suing for
their rights in their place of habitual residence (Switzerland) in
accordance with Clause 18(c) of the C2P SCCs; and (iv) references to
the ‘GDPR’ in the C2P SCCs will be understood as references to the
Swiss Federal Act on Data Protection insofar as the transfer of
Customer Personal Data is subject to the Swiss Federal Act on Data
Protection.

(c) With respect to transfers of Customer Personal Data originating

from the UK and subject to the UK GDPR, the Parties agree to comply
with the UK International Data Transfer Agreement (version A1.0)
issued by the UK Information Commissioner and laid before
Parliament in accordance with Section 119A of the Data Protection
Act 2018 on 2 February 2022 (as revised under its provisions) which
is incorporated herein by reference. The Parties agree that, for the
purposes of the UK IDTA:

(i) in Table 1, the Parties details and key contact information shall be
deemed completed with the relevant information set out in Annex I
to this DPA;

(ii) in Table 2, England and Wales is the governing law of the IDTA
and the primary place for legal claims to be made by the Parties; the
Exporter is a Controller and the importer is the Exporter’s Processor
or Sub-Processor; the UK GDPR applies to the Importer’s Processing
of the Transferred Data; reference to the “Linked Agreement” is to
this DPA; the term of the IDTA is the period for which the Linked
Agreement is in force; the Parties may end the IDTA (before the end
of the Terms or when the Approved IDTA changes) in accordance
with the termination provisions under the Agreement and this DPA;
the Importer MAY transfer on the Transferred Data to another
organization or person (who is a different legal entity) in accordance
with Section 16.1 (Transferring on the Transferred Data);the first
review date is the effective date of the Linked Agreement and the
Parties must review the Security Requirements at least once each
year]

(iii) in Table 3, the sections on details of Transferred Data shall be

deemed completed with the relevant details as set out in Annex I to
this DPA and this Transferred Data will update automatically if such
details are updated in the Linked Agreement;

(iv) in Table 4, the sections on security shall be deemed completed

with the security measures as described at Annex II to this DPA and
these Security Requirements will update automatically if such
security measures are updated in the Linked Agreement; and
(v) Part 4 Mandatory Clauses of the IDTA shall be deemed completed
with the following provision “Mandatory Clauses of the Approved
IDTA, being the template IDTA A.1.0 issued by the ICO and laid
before Parliament in accordance with s119A of the Data Protection
Act 2018 on 2 February 2022, as it is revised under Section 5.4 of
those Mandatory Clauses.”

(e) To the extent that the EU Standard Contractual Clauses are

subsequently modified, replaced, or held in a court of competent
jurisdiction to be invalid, Customer and MegaGroup hereby agree
that the applicable updated or new versions will be automatically
applied and incorporated to this DPA, as of the date of applicability.

(f) The Parties further agree that, to the extent Customer exercises a
termination right under the C2P SCCs, insofar as it concerns the
Processing of Personal Data under the C2P SCCs, MegaGroup shall
have the right to terminate the Agreement without penalty.

7. SUB-PROCESSING

(a) The Data Controller hereby grants the Data Processor general
written authorization to engage the Data Processor’s Affiliates as
Sub-Processors to Process Customer Personal Data and authorizes
the Data Processor and its Affiliates to engage third-party Sub-
Processors in connection with the delivery of services under the
Agreement, subject to the requirements of this Section 7. For the
avoidance of doubt, the above authorization constitutes Data
Controller’s prior written consent to the sub-Processing by Data
Processor for purposes of the Standard Contractual Clauses and the
IDTA. The Data Processor may engage new Sub-Processors or may
change Sub-Processors from time to time. The Data Processor will
provide the Data Controller with notice by updating the Sub-
Processor and by providing the Data Controller with a mechanism to
receive notice of such updates) of any new Sub-Processor at least
fifteen (15) days in advance of providing such Sub-Processor with
access to Customer Personal Data. The Data Controller will have
fourteen (14) days from the date of receipt of the Data Processor’s
notice to approve or reject the new Sub-Processor on reasonable
grounds. In the event of no response from the Data Controller, the
Sub-Processor will be deemed accepted. If the Data Controller
notifies MegaGroup of an objection to the new or replacement Sub-
Processor, the Parties will discuss Data Controller’s concerns in good
faith with a view to achieving a commercially reasonable resolution.
If no such resolution can be reached, either Party may terminate the
Processing of the Customer Personal Data with immediate effect, and
without liability to either Party, on written notice to the other Party.

(b) The Data Processor shall enter into written agreements with its
Sub-Processors containing data protection obligations that provide at
least the same level of protection for Customer Personal Data as
under this DPA and shall in particular impose on its Sub-Processors
the obligation to implement appropriate technical and organizational
measures in such a manner that the sub-Processing will meet the
requirements of Applicable Data Protection Law. Where a Sub-
Processor fails to fulfil its obligations, the Data Processor shall
remain fully liable under the Applicable Data Protection Law to the
Data Controller for the performance of that Sub-Processor’s
obligations.

8. RETURNING OR DESTRUCTION OF PERSONAL DATA

Upon termination of this DPA, upon the Data Controller’s written

request, or upon fulfillment of the Purpose whereby no further
Processing is required, the Data Processor shall, at the request of the
Data Controller, either delete, destroy or return all Customer
Personal Data to the Data Controller and destroy or return any
existing copies, except where otherwise required by applicable laws
of the EEA, EEA member states, the UK, or Switzerland. The return of
data may incur additional charges. The Data Processor agrees to
preserve the confidentiality of any retained Customer Personal Data
and will only Process such Customer Personal Data after the date of
termination in order to comply with those laws to which it is subject
and to fulfill its obligations under this DPA.

9. ASSISTANCE TO DATA CONTROLLER

(a) The Data Processor shall, to the extent legally permissible,

promptly notify the Data Controller of any requests from a Data
Subject to exercise the following rights of the Data Subject under the
Applicable Data Protection Law: access, rectification, restriction of
Processing, erasure (the “right to be forgotten”), data portability,
objection to the Processing, or to not be subject to automated
individual decision making (each a “Data Subject Request”).
Taking into the account the nature of the Processing, the Data
Processor shall assist the Data Controller by appropriate technical
and organizational measures, insofar as this is possible, for the
fulfilment of the Data Controller’s obligation to respond to the Data
Subject Request under Applicable Data Protection Law. In addition, to
the extent the Data Controller, in its use of the Services, does not
have the ability to address a Data Subject Request, the Data
Processor shall, upon the Data Controller’s request, use commercially
reasonable efforts to assist the Data Controller in responding to such
Data Subject Request, to the extent the Data Processor is legally
permitted to do so and the response to such Data Subject Request is
required under Applicable Data Protection Law.
(b) Upon the Data Controller’s request, taking into account the
nature of the Processing and the information available to the Data
Processor, the Data Processor shall provide the Data Controller with
reasonable cooperation and assistance to help the Data Controller
fulfill its obligations (if applicable) under the Applicable Data
Protection Law to (i) carry out a data protection impact assessment
related to the Data Controller’s use of the Services, to the extent the
Data Controller does not otherwise have access to the relevant
information, and (ii) engage in prior consultations with Regulators as
required under Article 36 of the GDPR or equivalent provision of the
Applicable Data Protection Law.

10. INFORMATION OBLIGATIONS AND INCIDENT

MANAGEMENT

(a) When the Data Processor becomes aware of a Personal Data

Breach, it shall notify the Data Controller at Data Controller’s
notification email address about the Personal Data Breach without
undue delay, shall provide commercially reasonable cooperation to
the Data Controller, and shall take commercially reasonable steps to
remediate the Personal Data Breach, if applicable, to the extent that
remediation is within the Data Processor’s control. At the Customer’s
request Data Processor will promptly provide the Customer with all
reasonable assistance necessary to enable the Customer to notify
relevant Personal Data Breaches to the Regulators and/or affected
Data Subjects, if Customer is required to do so under the Applicable
Data Protection Law. Customer is solely responsible for complying
with Personal Data Breach notification requirements applicable to
Customer and fulfilling any third-party notification obligations related
to any Personal Data Breach. The obligations of this Section 10(a) do
not apply to Personal Data Breaches that are caused by the Data
Controller, Users, and/or any products and services other than Data
Processor’s.

11. MISCELLANEOUS

(a) The liability of each Party and its respective Affiliates’, taken
together in the aggregate, arising out of or relating to this DPA shall
be subject to the section(s) of the Agreement governing limitations
of liability, and any reference in such section(s) to the liability of a
party means the aggregate liability of that party and all of its
Affiliates under the Agreement and all DPAs together.

(b) This DPA and any dispute or claim arising out of or in connection
with it or its subject matter or formation (including non-contractual
disputes and claims) shall be governed by and construed in
accordance with the laws applicable to the Agreement of which this
DPA forms a part.
(c) This DPA shall automatically terminate on the expiration or earlier
termination of the Agreement.

ANNEX I TO THE DPA

1. LIST OF PARTIES
2. Data exporter(s):

Name, address, contact person’s name, position and contact

details: Identity and contact details of the data exporter are as
identified in the Agreement between the Parties. Data exporter
(Customer) is the Controller.

Activities relevant to the data transferred under the C2P

SCCs: The receipt of Services under the Agreement.

Signature and date: Each of Data Processor’s and Customer’s

entering into this DPA shall be treated as each party’s signature of
this Annex I, Section A, of the C2P SCCs.

2. Data importer(s):

Name, address, contact person’s name, position and contact

details: Identity and contact details of the data importer, including
any contact person with responsibility for data protection as is
identified in the Agreement between the Parties. Data importer
(Webinauts) is the Processor.

Activities relevant to the data transferred under the C2P

SCCs: Provision of Services to Customer under the Agreement.

Signature and date: Each of Data Processor’s and Customer’s

entering into this DPA shall be treated as each party’s signature of
Annex I, Section A, of the C2P SCCs.

1. DESCRIPTION OF TRANSFER

Categories of data subjects whose personal data is

transferred: Data Controller’s employees, consultants, contractors,
agents, and/or third parties with whom the Data Controller conducts
business or collects through other means.
Categories of personal data transferred: The Personal Data that
may be Processed under the Agreement, as submitted by Customers
to or through the Services, may include, but is not limited to: first
and last name, title, position, contact information, IP address and
device ID.

Sensitive data transferred (if applicable) and applied

restrictions or safeguards that fully take into consideration
the nature of the data and the risks involved, such as for
instance strict purpose limitation, access restrictions
(including access only for staff having followed specialised
training), keeping a record of access to the data, restrictions
for onward transfers or additional security measures: None.
Customers are prohibited from including sensitive data or special
categories of data as part of the Customer Personal Data.

The frequency of the transfer (e.g. whether the data is

transferred on a one-off or continuous basis): Continuous, for
as long as the Customer uses the Services.

Nature of the processing: The nature of Processing is the

provision of the Services to the Customer that involves the
Processing of Customer Personal Data. Customer Personal Data will
be subject to those Processing activities which Data Processor needs
to perform in order to provide the Services pursuant to the
Agreement.

Purpose(s) of the data transfer and further

processing: Customer Personal Data will be Processed for the
Purposes (as defined by Section 2 of this DPA).

The period for which the personal data will be retained, or, if
that is not possible, the criteria used to determine that
period: For the duration of the Agreement.

For transfers to (sub-) processors, also specify subject

matter, nature and duration of the processing: As described in
Section 7 of this DPA.

1. COMPETENT SUPERVISORY AUTHORITY

Identify the competent supervisory authority/ies in

accordance with Clause 13 of the C2P SCCs: The supervisory
authority of Czech Republic.
ANNEX II TO THE DPA

MegaGroup may update or modify these security measures from time

to time provided that such updates and modifications do not result in
the degradation of the overall security of the Services.

1. Data Center

 MegaGroup stores all production data in physically secure data

centers.
 Infrastructure systems have been designed to eliminate single
points of failure and minimize the impact of anticipated
environmental risks. Dual circuits, switches, networks or other
necessary devices help provide this redundancy. The Services
are designed to allow MegaGroup to perform certain types of
preventative and corrective maintenance without interruption.
All environmental equipment and facilities have documented
preventative maintenance procedures that detail the process
for and frequency of performance in accordance with the
manufacturer’s or internal specifications. Preventative and
corrective maintenance of the data center equipment is
scheduled through a standard change process according to
documented procedures.
 The data center electrical power systems are designed to be
redundant and maintainable without impact to continuous
operations, 24 hours a day, and 7 days a week. In most cases, a
primary as well as an alternate power source, each with equal
capacity, is provided for critical infrastructure components in
the data center. Backup power is provided by various
mechanisms such as uninterruptible power supplies (UPS)
batteries, which supply consistently reliable power protection
during utility brownouts, blackouts, over voltage, under
voltage, and out-of-tolerance frequency conditions. If utility
power is interrupted, backup power is designed to provide
transitory power to the data center, at full capacity, for up to
10 minutes until the diesel generator systems take over. The
diesel generators are capable of automatically starting up
within seconds to provide enough emergency electrical power
to run the data center at full capacity typically for a period of
days.
 MegaGroup has designed and regularly plans and tests its
business continuity planning/disaster recovery checks.
 When user data is copied electronically by MegaGroup outside
the data center, appropriate physical security is maintained,
and the data is encrypted at all times.
 1. Access Control

 Preventing Unauthorized Services Access:

1. MegaGroup hosts its Service with outsourced cloud

infrastructure providers.
2. Additionally, MegaGroup maintains contractual relationships
with vendors in order to provide the Service in accordance with
DPA. MegaGroup relies on contractual agreements, privacy
policies, and vendor compliance procedures in order to protect
data processed or stored by these vendors.
3. MegaGroup hosts its Services infrastructure with multi-tenant,
outsourced infrastructure providers.
4. MegaGroup implemented a uniform password policy for its
Services and correspondent tools and features. All passwords
must fulfil defined minimum requirements and are stored in
encrypted form. Users who interact with the Services via the
user interface must authenticate before accessing non-public
user data.
5. User data is stored in multi-tenant storage systems accessible
to users via only application user interfaces and application
programming interfaces. Users are not allowed direct access to
the underlying application infrastructure. The authorization
model in each of the tools and features of the Services is
designed to ensure that only the appropriately assigned
individuals can access relevant features, views, and
customization options. Authorization to data sets is performed
through validating the user’s permissions.
6. Public Services APIs may be accessed using an API key.
 Preventing Unauthorized Services Use. MegaGroup utilizes the following access
controls and detection capabilities for the internal networks that support its Services:

1. Network access control mechanisms are designed to prevent

network traffic using unauthorized protocols from reaching the
Services infrastructure. The technical measures implemented
differ between infrastructure providers and include Virtual
Private Cloud (VPC) implementations, security group
assignment, and traditional firewall rules.
2. MegaGroup implemented a Web Application Firewall (WAF)
solution to protect internet-accessible applications. The WAF is
designed to identify and prevent attacks against publicly
available network services.
3. Security reviews of the parts of code stored in MegaGroup
source code repositories are performed, checking for coding
best practices and identifiable software flaws.
4. MegaGroup conducts penetration tests annually. The intent of
the penetration tests is to identify and resolve foreseeable
attack vectors and potential abuse scenarios.
 5. A bug bounty program invites and incentivizes independent
security researchers to ethically discover and disclose security
flaws. MegaGroup implemented a bug bounty program in an
effort to widen the available opportunities to engage with the
security community and improve the Services defenses against
sophisticated attacks.
 Authorization Requirements. A subset of MegaGroup and MegaGroup affiliates’
employees have access to user data via controlled interfaces. The intent of providing access
to a subset of employees is to provide effective customer support, to troubleshoot potential
problems, to detect and respond to security incidents and implement data security.
MegaGroup and MegaGroup affiliates’ employees are required to conduct themselves
in a manner consistent with the MegaGroup guidelines regarding confidentiality, business
ethics, appropriate usage, and professional standards.

1. Transmission Control

MegaGroup makes HTTPS encryption (also referred to as SSL or TLS)

available on every one of its login interfaces. MegaGroup HTTPS
implementation uses industry standard algorithms and certificates.

1. Input Control

 MegaGroup designed its infrastructure to log extensive

information about the system behavior, traffic received, system
authentication, and other application requests partly. Internal
systems aggregate log data and alert appropriate employees of
malicious, unintended, or anomalous activities. MegaGroup
personnel, including security, are responsive to known
incidents.
 MegaGroup maintains a record of known security incidents that
includes description, dates and times of relevant activities, and
incident disposition. Suspected and confirmed security
incidents are investigated by security, operations, or support
personnel; and appropriate resolution steps are identified and
documented. For any confirmed incidents, MegaGroup will take
appropriate steps to minimize User damage or unauthorized
disclosure.
 If MegaGroup becomes aware of unlawful access to MegaGroup
data stored within its Services, MegaGroup will:

1. notify the affected Users of the incident;

2. provide a description of the steps MegaGroup is taking to
resolve the incident; and
3. provide status updates to the User contact, as MegaGroup
deems necessary.
 Notification(s) of incidents, if any, will be delivered to one or more of the User’s contacts
in a form MegaGroup selects, which may include via email or telephone.

1. Availability Control
  The infrastructure providers use commercially reasonable
efforts to ensure a minimum of 99.8% uptime. The providers
maintain a minimum of N+1 redundancy to power, network,
and HVAC services.
 Backup and replication strategies are designed to ensure
redundancy and fail-over protections during a significant
processing failure. M data is backed up to multiple durable data
stores and replicated across multiple availability zones.
MegaGroup uses commercially reasonable efforts to create
frequent, encrypted back-up copies of Protected Data and these
are stored in geographically separate locations.
 Where feasible, production databases are designed to replicate
data between no less than 1 primary and 1 secondary
database. All databases are backed up and maintained using at
least industry standard methods.

The Services are designed to ensure redundancy and seamless

failover. The server instances that support the Services are also
architected with a goal to prevent single points of failure. This design
assists MegaGroup operations in maintaining and updating the
Services applications and backend while limiting downtime.