Data Processing Agreement

ASection A

Defined Terms

This Data Processing Agreement ("DPA") is incorporated into and is subject to the terms and conditions of the Agreement between Franstorm AI LLC and the customer entity that is a party to the Agreement ("Customer" or "you"). All capitalized terms not defined in this DPA shall have the meanings set forth in the Agreement.

BSection B

Obligations of Franstorm AI LLC

Compliance

Franstorm AI shall, and shall ensure that its Personnel, agents, and Subprocessors comply with all applicable Data Protection Laws.

Security

Franstorm AI represents and warrants that it implements appropriate technical and organizational measures to protect Relevant Personal Data in accordance with Articles 32–34 of the GDPR, designed to prevent unauthorized access, alteration, loss, or destruction of data. Franstorm AI conducts regular internal security reviews and maintains updated documentation of its security framework.

Roles

The Parties acknowledge that the Customer is the Controller and Franstorm AI is the Processor. Franstorm AI shall:

• Process Personal Data only as instructed by the Customer and in compliance with applicable laws.
• Notify the Customer promptly if it cannot comply with any instruction due to legal obligations.
• Maintain complete, accurate, and current records of all processing activities for at least four (4) years and provide such records upon request.
• Ensure confidentiality by limiting data access to authorized Personnel and Subprocessors, and requiring confidentiality commitments from all Personnel and Subprocessors.

Subprocessors

Franstorm AI shall only engage Subprocessors with prior written authorization from the Customer and shall ensure Subprocessors are bound by equivalent obligations as those in this Agreement.

Data Subject Rights

At the Customer's request and expense, Franstorm AI will provide reasonable assistance to respond to Data Subject access or deletion requests.

Deletion or return of data

Within 30 days of termination or expiration of the Agreement, Franstorm AI shall permanently and securely delete or return all Relevant Personal Data, unless retention is required by law.

Audits

At the Customer's request and expense, Franstorm AI shall provide audit access to demonstrate compliance with this DPA and Data Protection Laws.

CSection C

General

Term

This Agreement shall commence upon execution and automatically terminate when the Services Agreement expires or is terminated.

Counterparts

This Agreement may be executed in counterparts, each constituting an original.

Governing law

This Agreement shall be governed by and construed in accordance with the laws of England and Wales, and disputes shall be subject to the exclusive jurisdiction of the English courts.

DSection D

Security

Cloud infrastructure

Franstorm AI operates entirely in the cloud and does not manage on-premise routers, servers, or hardware.

Infrastructure provider

Franstorm AI's infrastructure is hosted on Amazon Web Services (AWS), which maintains industry-leading security certifications and compliance standards.

Data pseudonymization

Personal Data is pseudonymized wherever possible, ensuring non-essential identifiers are truncated to protect Data Subject privacy.

Security & compliance

For full details on technical and organizational measures, refer to our Security & Compliance Policy at www.franstorm.com/security.

ESection E

Schedule 1 — Data Processing Activities

Scope of processing

Franstorm AI's fulfillment of its obligations under the Services Agreement will involve provision of automation and CRM services, and service improvement, analytics, and updates.

Duration

Processing of Relevant Personal Data continues for the duration of the Agreement and any legally required retention period.

Data subjects

• Customer Personnel
• Customer's clients and prospects
• End-users of Customer's services or integrations

Categories of Personal Data

Purposes of processing

• Providing and maintaining Franstorm AI's automation platform.
• Managing customer accounts and technical support.
• Enhancing service functionality and security.
• Ensuring compliance with applicable legal obligations.

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