Data Processing Addendum

This Data Processing Addendum (DPA) is entered into by and between Poly Hammer and the user. This DPA supplements the terms of the existing agreement(s) governing the services provided by the Poly Hammer to the Customer.

1. Definitions

• Personal Data: Any information relating to an identified or identifiable natural person processed by the Poly Hammer on behalf of the Customer.
• Processing: Any operation performed on Personal Data, such as collection, storage, use, disclosure, or deletion.
• User Analytics Collection Tool: A tool used to collect logs, performance data, and user interactions to support debugging, error tracking, and product optimization.
• Subprocessor: Any third party engaged by Poly Hammer to assist in processing Personal Data.

2. Roles and Responsibilities

The Customer acts as the Data Controller, and Poly Hammer acts as the Data Processor. Poly Hammer will only process Personal Data as instructed by the Customer and in compliance with applicable privacy laws, including processing logs and user data collected through the user analytics collection tool for debugging and optimization.

3. Purpose of Processing

Poly Hammer will process Personal Data to provide services as described in the agreement, which may include debugging, crash reporting, performance monitoring, and optimization Poly Hammer products through the use of a user analytics collection tool.

4. Data Security

Poly Hammer will implement appropriate technical and organizational measures to protect Personal Data, including logs and user data collected through the user analytics collection tool, against unauthorized access, loss, or destruction.

5. Subprocessors

Poly Hammer may engage Subprocessors to assist in processing Personal Data. The Customer will be notified of any new Subprocessors and may object on reasonable grounds. Subprocessors may be used to support the functionality of the user analytics collection tool.

6. Data Subject Rights

The Service Provider will assist the Customer in fulfilling requests from data subjects to access, correct, delete, or restrict their Personal Data, including any data collected through the user analytics collection tool.

7. Data Transfers

The Service Provider will ensure that Personal Data, including logs and user data, transferred outside the Customer's jurisdiction complies with applicable data transfer mechanisms, such as Standard Contractual Clauses or Data Privacy Frameworks.

8. Data Breach Notification

The Service Provider will notify the Customer without undue delay upon becoming aware of a breach involving Personal Data, including any data processed by the user analytics collection tool.

9. Term and Deletion

Upon termination of the agreement, the Service Provider will delete or return all Personal Data, including logs and user data from the user analytics collection tool, as instructed by the Customer, unless retention is required by law.