Annex I — Data Processing Agreement (Customers within EEA)

Data Processing Agreement

For Customers established within the European Economic Area

Last update: 05/18/2026

This Annex I (EU) (Data Processing Agreement, the "DPA") forms part of the Software as a Service Agreement (the "SSA") between Maestra B.V. ("Provider" or "Processor") and the Customer identified in the Engagement Letter ("Customer" or "Controller"). This DPA applies whenever Customer is established within the European Economic Area (EEA) and Provider Processes Personal Data on behalf of Customer through the Services.

Capitalized terms not defined in this DPA have the meanings given in the SSA. Where the terms used in this DPA are defined in the GDPR, those terms shall have the same meaning as in the GDPR.

Section I — General

Clause 1 — Purpose and Scope

The purpose of these standard contractual clauses (the "Clauses") is to ensure compliance with Article 28(3) and (4) of the GDPR for the Processing of Personal Data by the Processor on behalf of the Controller.
The Parties have agreed to these Clauses in order to ensure compliance with Article 28(3) and (4) of the GDPR.
These Clauses apply to the Processing of Personal Data as specified in Annex II to this DPA.
Annexes I to III to this DPA are an integral part of these Clauses.
These Clauses are without prejudice to obligations to which the Controller is subject by virtue of the GDPR.
These Clauses do not by themselves ensure compliance with obligations related to international transfers in accordance with Chapter V of the GDPR.

Clause 2 — Invariability of the Clauses

The Parties undertake not to modify the Clauses, except for adding information to the Annexes or updating information in them.
This does not prevent the Parties from including the standard contractual clauses laid down in these Clauses in a broader contract, or from adding other clauses or additional safeguards provided that they do not directly or indirectly contradict the Clauses or detract from the fundamental rights or freedoms of data subjects.

Clause 3 — Interpretation

Where these Clauses use the terms defined in the GDPR, those terms shall have the same meaning as in that Regulation.
These Clauses shall be read and interpreted in the light of the provisions of the GDPR.
These Clauses shall not be interpreted in a way that runs counter to the rights and obligations provided for in the GDPR or in a way that prejudices the fundamental rights or freedoms of the data subjects.

Clause 4 — Hierarchy

In the event of a contradiction between these Clauses and the provisions of related agreements between the Parties existing at the time when these Clauses are agreed or entered into thereafter, these Clauses shall prevail.

Clause 5 — Docking Clause (Optional)

Any entity that is not a Party to these Clauses may, with the agreement of all the Parties, accede to these Clauses at any time as a controller or a processor by completing the Annexes and signing Annex I.
Once the Annexes referred to in paragraph (a) are completed and signed, the acceding entity shall be treated as a Party to these Clauses and have the rights and obligations of a controller or a processor, in accordance with its designation in Annex I.
The acceding entity shall have no rights or obligations resulting from these Clauses from the period prior to becoming a Party.

Section II — Obligations of the Parties

Clause 6 — Description of Processing

The details of the Processing operations, in particular the categories of Personal Data and the purposes of Processing for which the Personal Data is Processed on behalf of the Controller, are specified in Annex II to this DPA.

Clause 7 — Obligations of the Parties

7.1 Instructions

The Processor shall Process Personal Data only on documented instructions from the Controller, unless required to do so by Union or Member State law to which the Processor is subject. In this case, the Processor shall inform the Controller of that legal requirement before Processing, unless the law prohibits this on important grounds of public interest. Subsequent instructions may also be given by the Controller throughout the duration of the Processing of Personal Data. These instructions shall always be documented.
The Processor shall immediately inform the Controller if, in the Processor’s opinion, instructions given by the Controller infringe the GDPR or the applicable Union or Member State data protection provisions.

7.2 Purpose Limitation

The Processor shall Process the Personal Data only for the specific purpose(s) of the Processing, as set out in Annex II to this DPA, unless it receives further instructions from the Controller.

7.3 Duration of the Processing of Personal Data

Processing by the Processor shall only take place for the duration specified in Annex II to this DPA.

7.4 Security of Processing

The Processor shall at least implement the technical and organisational measures specified in Annex III to this DPA to ensure the security of the Personal Data. This includes protecting the data against a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access to the data (personal data breach). In assessing the appropriate level of security, the Parties shall take due account of the state of the art, the costs of implementation, the nature, scope, context and purposes of Processing and the risks involved for the data subjects.
The Processor shall grant access to the Personal Data undergoing Processing to members of its personnel only to the extent strictly necessary for implementing, managing and monitoring of the contract. The Processor shall ensure that persons authorised to Process the Personal Data received have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality.

7.5 Sensitive Data

If the Processing involves Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data or biometric data for the purpose of uniquely identifying a natural person, data concerning health or a person’s sex life or sexual orientation, or data relating to criminal convictions and offences ("sensitive data"), the Processor shall apply specific restrictions and/or additional safeguards.

7.6 Documentation and Compliance

The Parties shall be able to demonstrate compliance with these Clauses.
The Processor shall deal promptly and adequately with inquiries from the Controller about the Processing of data in accordance with these Clauses.
The Processor shall make available to the Controller all information necessary to demonstrate compliance with the obligations that are set out in these Clauses and stem directly from the GDPR. At the Controller’s request, the Processor shall also permit and contribute to audits of the Processing activities covered by these Clauses, at reasonable intervals or if there are indications of non-compliance. In deciding on a review or an audit, the Controller may take into account relevant certifications held by the Processor.
The Controller may choose to conduct the audit by itself or mandate an independent auditor. Audits may also include inspections at the premises or physical facilities of the Processor and shall, where appropriate, be carried out with reasonable notice.
The Parties shall make the information referred to in this Clause, including the results of any audits, available to the competent supervisory authority/ies on request.

7.7 Use of Sub-Processors

GENERAL WRITTEN AUTHORISATION: The Processor has the Controller’s general authorisation for the engagement of sub-processors from an agreed list. The Processor shall specifically inform in writing the Controller of any intended changes of that list through the addition or replacement of sub-processors at least thirty (30) calendar days in advance, thereby giving the Controller sufficient time to be able to object to such changes prior to the engagement of the concerned sub-processor(s). The Processor shall provide the Controller with the information necessary to enable the Controller to exercise the right to object. Notwithstanding the foregoing, where the Processor needs to add or replace a sub-processor on shorter notice due to (i) the sub-processor’s insolvency, (ii) a material security incident affecting the sub-processor, (iii) the sub-processor’s material breach of its data protection obligations, or (iv) any other circumstance requiring immediate action to protect the security or integrity of the Services or the Personal Data, the Processor may make such addition or replacement on as much advance notice as is reasonably practicable (and in any event with not less than five (5) working days’ notice where reasonably possible), with prompt notice to the Controller of the circumstances justifying the shortened notice period.
Where the Processor engages a sub-processor for carrying out specific Processing activities (on behalf of the Controller), it shall do so by way of a contract which imposes on the sub-processor, in substance, the same data protection obligations as the ones imposed on the Processor in accordance with these Clauses. The Processor shall ensure that the sub-processor complies with the obligations to which the Processor is subject pursuant to these Clauses and to the GDPR.
At the Controller’s request, the Processor shall provide a copy of such a sub-processor agreement and any subsequent amendments to the Controller. To the extent necessary to protect business secret or other confidential information, including Personal Data, the Processor may redact the text of the agreement prior to sharing the copy.
The Processor shall remain fully responsible to the Controller for the performance of the sub-processor’s obligations in accordance with its contract with the Processor. The Processor shall notify the Controller of any failure by the sub-processor to fulfil its contractual obligations.
The Processor shall agree a third party beneficiary clause with the sub-processor whereby — in the event the Processor has factually disappeared, ceased to exist in law or has become insolvent — the Controller shall have the right to terminate the sub-processor contract and to instruct the sub-processor to erase or return the Personal Data.

7.8 International Transfers

Any transfer of data to a third country or an international organisation by the Processor shall be done only on the basis of documented instructions from the Controller or in order to fulfil a specific requirement under Union or Member State law to which the Processor is subject and shall take place in compliance with Chapter V of the GDPR.
The Controller agrees that where the Processor engages a sub-processor in accordance with Clause 7.7 for carrying out specific Processing activities (on behalf of the Controller) and those Processing activities involve a transfer of Personal Data within the meaning of Chapter V of the GDPR, the Processor and the sub-processor can ensure compliance with Chapter V of the GDPR by using standard contractual clauses adopted by the Commission in accordance with Article 46(2) of the GDPR, provided the conditions for the use of those standard contractual clauses are met.

Clause 8 — Assistance to the Controller

The Processor shall promptly notify the Controller of any request it has received from the data subject. It shall not respond to the request itself, unless authorised to do so by the Controller.
The Processor shall assist the Controller in fulfilling its obligations to respond to data subjects’ requests to exercise their rights, taking into account the nature of the Processing. In fulfilling its obligations in accordance with paragraphs (a) and (b), the Processor shall comply with the Controller’s instructions.
In addition to the Processor’s obligation to assist the Controller pursuant to Clause 8(b), the Processor shall furthermore assist the Controller in ensuring compliance with the following obligations, taking into account the nature of the data Processing and the information available to the Processor: (i) the obligation to carry out a data protection impact assessment where a type of Processing is likely to result in a high risk to the rights and freedoms of natural persons; (ii) the obligation to consult the competent supervisory authority/ies prior to Processing where a data protection impact assessment indicates that the Processing would result in a high risk in the absence of measures taken by the Controller to mitigate the risk; (iii) the obligation to ensure that Personal Data is accurate and up to date, by informing the Controller without delay if the Processor becomes aware that the Personal Data it is Processing is inaccurate or has become outdated; (iv) the obligations in Article 32 of the GDPR.
The Parties shall set out in Annex III to this DPA the appropriate technical and organisational measures by which the Processor is required to assist the Controller in the application of this Clause as well as the scope and the extent of the assistance required.

Clause 9 — Notification of Personal Data Breach

In the event of a personal data breach, the Processor shall cooperate with and assist the Controller for the Controller to comply with its obligations under Articles 33 and 34 of the GDPR, taking into account the nature of Processing and the information available to the Processor.

9.1 Data Breach Concerning Data Processed by the Controller

In the event of a personal data breach concerning data Processed by the Controller, the Processor shall assist the Controller:

in notifying the personal data breach to the competent supervisory authority/ies, without undue delay after the Controller has become aware of it, where relevant (unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons);
in obtaining the following information which, pursuant to Article 33(3) of the GDPR, shall be stated in the Controller’s notification, and must at least include: (1) the nature of the Personal Data including where possible, the categories and approximate number of data subjects concerned and the categories and approximate number of Personal Data records concerned; (2) the likely consequences of the personal data breach; (3) the measures taken or proposed to be taken by the Controller to address the personal data breach, including, where appropriate, measures to mitigate its possible adverse effects;
in complying, pursuant to Article 34 of the GDPR, with the obligation to communicate without undue delay the personal data breach to the data subject, when the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons.

Where, and insofar as, it is not possible to provide all this information at the same time, the initial notification shall contain the information then available and further information shall, as it becomes available, subsequently be provided without undue delay.

9.2 Data Breach Concerning Data Processed by the Processor

In the event of a personal data breach concerning data Processed by the Processor, the Processor shall notify the Controller without undue delay after the Processor having become aware of the breach. Such notification shall contain, at least:

a description of the nature of the breach (including, where possible, the categories and approximate number of data subjects and data records concerned);
the details of a contact point where more information concerning the personal data breach can be obtained;
its likely consequences and the measures taken or proposed to be taken to address the breach, including to mitigate its possible adverse effects.

Section III — Final Provisions

Clause 10 — Non-compliance with the Clauses and Termination

Without prejudice to any provisions of the GDPR, in the event that the Processor is in breach of its obligations under these Clauses, the Controller may instruct the Processor to suspend the Processing of Personal Data until the latter complies with these Clauses or the contract is terminated. The Processor shall promptly inform the Controller in case it is unable to comply with these Clauses, for whatever reason.
The Controller shall be entitled to terminate the contract insofar as it concerns Processing of Personal Data in accordance with these Clauses if: (1) the Processing of Personal Data by the Processor has been suspended by the Controller pursuant to point (a) and if compliance with these Clauses is not restored within a reasonable time and in any event within one month following suspension; (2) the Processor is in substantial or persistent breach of these Clauses or its obligations under the GDPR; (3) the Processor fails to comply with a binding decision of a competent court or the competent supervisory authority/ies regarding its obligations pursuant to these Clauses or to the GDPR.
The Processor shall be entitled to terminate the contract insofar as it concerns Processing of Personal Data under these Clauses where, after having informed the Controller that its instructions infringe applicable legal requirements in accordance with Clause 7.1(b), the Controller insists on compliance with the instructions.
Following termination of the contract, the Processor shall, at the choice of the Controller, delete all Personal Data Processed on behalf of the Controller and certify to the Controller that it has done so, or return all the Personal Data to the Controller and delete existing copies unless Union or Member State law requires storage of the Personal Data. Until the data is deleted or returned, the Processor shall continue to ensure compliance with these Clauses. For the avoidance of doubt, this Clause 10(d) does not apply to Resultant Data, which is governed by Section 10.1 of the SSA.

Annex I to the DPA — List of Parties

A. Controller

Name: Customer, as identified in the Engagement Letter.

Address: as set forth in the Engagement Letter.

Contact person’s name, position and contact details: as set forth in the Engagement Letter.

Activities relevant to the data transferred under these Clauses: Processings indicated in Annex II to this DPA.

Role: controller.

B. Processor

Name: Maestra B.V.

Address: as set forth in the Engagement Letter.

Contact person’s name, position and contact details: Data Privacy Manager, dpo@maestra.io

Activities relevant to the data transferred under these Clauses: provider of the Maestra Service, a software platform for marketing automation distributed as Software-as-a-Service, in the course of which Maestra B.V. Processes certain Personal Data as a Processor.

Role: processor.

Annex II to the DPA — Description of Processing

Frequency and Duration of the Processing

The Personal Data is Processed on a continuous basis throughout the Term of the SSA. The Personal Data is deleted within thirty (30) days after the termination of the SSA, plus a further period of up to six (6) months thereafter for the removal of backups. Resultant Data is retained by the Processor indefinitely in accordance with Section 10.1 of the SSA.

Sub-processors

For the purpose of providing the Services, the Processor engages sub-processors as set forth below. Sub-processors are organised into two categories: Core sub-processors (engaged for every Controller) and Module-specific sub-processors (engaged only when the Controller activates the relevant module). Detailed sub-processor information for each Processing purpose is set forth in the descriptions of each Processing operation below.

Core sub-processors (engaged for every Controller):

Amazon Web Services EMEA SARL (EEA) — cloud infrastructure hosting and storage of Personal Data;
Microsoft Corporation — Azure (EEA) — cloud infrastructure hosting and storage of Personal Data;
Leaseweb Deutschland GmbH (Germany, EEA) — data centre and dedicated server hosting;
Google LLC (United States) — mobile push notification delivery via Firebase Cloud Messaging to Android devices; web push notification delivery via Firebase Cloud Messaging. Transfers covered by standard contractual clauses pursuant to Commission Implementing Decision (EU) 2021/914;
Apple Inc. (United States) — mobile push notification delivery via Apple Push Notification Service (APNs) to iOS devices. Transfers covered by standard contractual clauses pursuant to Commission Implementing Decision (EU) 2021/914.

Module-specific sub-processors (engaged only when the Controller activates the relevant module):

Albato Limited (EEA) — engaged only when the Controller activates the Ad Optimization module. Albato hosts Personal Data with Amazon Web Services. The onward transfer from Albato to Amazon Web Services in the United States is covered by standard contractual clauses adopted by the European Commission pursuant to Commission Implementing Decision (EU) 2021/914 between Albato and Amazon Web Services. Albato is contractually required under its agreement with the Processor to maintain such Chapter V safeguards for any onward transfer of Personal Data to a third country;
Huawei Technologies Co. Ltd. (China) — engaged only when the Controller activates the Mobile App SDK / Huawei module. Where activated, Personal Data transferred to Huawei consists of push notification tokens, device identifiers, and message content. The Controller acknowledges that this involves a transfer of Personal Data to the People’s Republic of China, which is not the subject of an adequacy decision under Article 45 of the GDPR. Huawei is contractually required under its agreement with the Processor to implement appropriate transfer safeguards under Chapter V of the GDPR. The Controller is responsible for providing the corresponding Article 13 / Article 14 information notices to its End Customers prior to enabling the Huawei push channel.

The Processor shall give notice of any addition or replacement of a sub-processor in accordance with Clause 7.7 of this DPA.

I. Processings of Controller’s End Customers’ Data

The categories of data subjects whose Personal Data is Processed under this DPA include End Customers of the Controller (natural persons receiving marketing communications from the Controller through the Services).

Maestra CDP

1. PURPOSE: Creating an End Customer profile in the CDP

Categories of personal data processed

Maestra ID (End Customer)
Name
Email
Phone number
IP address
Gender
Date of birth
Type of device and display resolution
Additional info from comment fields
Extra fields added by Controller
Browser type and version
Geographic location (country or town)
Registration date

Nature of the processing

Registration of the Controller’s End Customer in the Maestra Service.

Sub-processors, subject matter, nature and duration of processing

The data are stored on the servers of Microsoft Corporation, Leaseweb Deutschland GmbH, and Amazon Web Services, within the European Economic Area. The data are deleted in accordance with the storage period identified for this processing.

2. PURPOSE: Merging profiles of the same End Customer

Categories of personal data processed

Email
Phone number
App ID
Web ID
Order number
Bank card hash
Maestra ID (End Customer)

Nature of the processing

When more than one profile of the same End Customer exists, the data contained in those profiles is merged and presented to the Controller as the data of one End Customer.

Sub-processors, subject matter, nature and duration of processing

The same as described for purpose 1 above.

3. PURPOSE: Saving the history of End Customer actions on the Controller’s website, interactions with mailing lists etc.

Categories of personal data processed

Pages opened
Buttons clicked
Email opening rate
Orders history
Product list interactions
Information about the loyalty program
Maestra ID (End Customer)
Information about the lead form where the request was left
Whether End Customer is logged in to the site
Loyalty card activation
Bonuses accrual
Product categories browsing history
Product browsing history
Subscription status
Other actions

Nature of the processing

Actions of the Controller’s End Customer are transferred to the Maestra Service to configure marketing campaigns more efficiently.

Sub-processors, subject matter, nature and duration of processing

The same as described for purpose 1 above.

4. PURPOSE: CDP segmentation (by behavior, purchases, and other personal data)

Categories of personal data processed

Segment
Maestra ID (End Customer)
Phone number
IP address
Gender
Date of birth
Pages opened
Buttons clicked
Email opening rate
Orders history
Product lists
Information about the loyalty program
Whether End Customer is logged in to the site
Loyalty card activation
Bonuses accrual
Product categories viewed
Products viewed
Subscription status
Other actions
Device UUID

Nature of the processing

Adding End Customers to particular segments based on parameters defined by the Controller.

Sub-processors, subject matter, nature and duration of processing

The same as described for purpose 1 above.

5. PURPOSE: Building communication workflows

Categories of personal data processed

Behavioral trigger
Maestra ID (End Customer)

Nature of the processing

The Controller indicates which action the Maestra Service should perform with regard to its End Customers based on different parameters.

Sub-processors, subject matter, nature and duration of processing

The same as described for purpose 1 above.

6. PURPOSE: Retention marketing

Categories of personal data processed

Name
Phone number
Email
Orders history
Order amount

Nature of the processing

Conditions for retention marketing are defined by the Controller. The Maestra Service interacts with End Customers in accordance with prescribed scenarios.

Sub-processors, subject matter, nature and duration of processing

The same as described for purpose 1 above.

7. PURPOSE: Targeting by personal data and behavior on the site

Categories of personal data processed

Segment
Maestra ID (End Customer)
Phone number
IP address
Gender
Date of birth
Pages opened
Buttons clicked
Email opening rate
Orders history
Product lists
Information about the loyalty program
Other actions

Nature of the processing

The Maestra Service analyses End Customer behavior on the Controller’s website. Based on the analytics, the Controller defines further marketing activities for particular behavior patterns.

Sub-processors, subject matter, nature and duration of processing

The same as described for purpose 1 above.

Maestra Product Recommendations — Best Sending Time

8. PURPOSE: Automated email sending at the best possible time (machine-learning-driven algorithm)

Categories of personal data processed

Email
Automatically generated time of sending

Nature of the processing

The Maestra Service determines which time of newsletter sending is most appropriate for a particular End Customer and sends the message.

Sub-processors, subject matter, nature and duration of processing

The same as described for purpose 1 above.

9. PURPOSE: Determine the best time to send

Categories of personal data processed

Average open rate
Average click rate
Name
Surname
Maestra ID (End Customer)
Distribution of the most appropriate time to send messages by days
History of End Customer interaction with products, newsletters, etc.
Email
Phone number
Brand
Contact point
Region

Nature of the processing

This algorithm automatically determines the best campaign sending time for each End Customer.

Sub-processors, subject matter, nature and duration of processing

The same as described for purpose 1 above.

Maestra Campaign Modules

10. PURPOSE: Email campaigns

Categories of personal data processed

Segment
Email
Subscription status
Behavioral trigger
Order/delivery status
Name
Date of birth

Nature of the processing

Bulk, automated, and transactional email campaigns sent via the Maestra Service interface.

Sub-processors, subject matter, nature and duration of processing

The same as described for purpose 1 above.

11. PURPOSE: SMS campaigns

Categories of personal data processed

Segment
Phone number
Subscription status

Nature of the processing

Bulk, automated, and transactional SMS campaigns sent via the Maestra Service interface through external SMS gateways.

Sub-processors, subject matter, nature and duration of processing

The same as described for purpose 1 above.

12. PURPOSE: Mobile push notification campaigns

Categories of personal data processed

Segment
Subscription status
Filter indicated by Controller
Clicks on the push
Sender ID
ID of the project in Firebase
Secret key
Tracker (configuration of service worker and Firebase parameters)
Device settings concerning sending mobile pushes

Nature of the processing

Bulk, automated, and transactional campaigns sent via mobile push notifications. Notifications are delivered to Android phone users through Firebase Cloud Messaging (Google LLC, USA) and to iPhone users through Apple Push Notifications (Apple Inc., USA). Where the Controller activates the Mobile App SDK / Huawei module, notifications to Huawei devices are also delivered through Push Kit (Huawei Technologies Co. Ltd., China); this channel is opt-in and is engaged only when the Controller has activated the relevant module.

Sub-processors, subject matter, nature and duration of processing

The same as described for purpose 1 above.

13. PURPOSE: Sending web pushes

Categories of personal data processed

Segment
Subscription status
Filter indicated by Controller
Clicks on the push
Whether the browser allows push notifications
Token (if the browser allows push notifications)
Sender ID, ID of the project in Firebase
Secret key
Tracker (configuration of service worker and Firebase parameters)

Nature of the processing

Based on parameters indicated by the Controller and the matching behavior of End Customers, End Customers receive push notifications in their web browsers. The Maestra Service uses Firebase Cloud Messaging (Google LLC, USA) to send web pushes.

Sub-processors, subject matter, nature and duration of processing

The same as described for purpose 1 above.

Maestra Website Personalization

14. PURPOSE: Customization of pop-ups, banners, embeddings and widgets

Categories of personal data processed

Segment
Email
Name
Subscription status
UTM tags
URL from which the new lead was obtained
Domain
City
City ID
Date and time of creation
Number of purchases
Orders history
History of End Customer interaction with products, newsletters, etc.
Time spent on the website
Bonuses accrual
Phone number
Promocode
History of website visits
Type of device and display resolution
Comments left in forms
Items in the shopping bag
Traffic source for the visitor
Actions on the website page

Nature of the processing

Based on parameters indicated by the Controller and the matching behavior of End Customers, End Customers see personalized content on websites and mobile applications.

Sub-processors, subject matter, nature and duration of processing

The same as described for purpose 1 above.

Maestra Ad Optimization (opt-in module)

The processings in this section apply only when the Controller activates the Ad Optimization module. The Controller has the right to enable or disable this module at any time.

15. PURPOSE: Integration with advertising tools (opt-in)

Categories of personal data processed

Controller’s database
Segment
Email
Phone number
Gender
Date of birth
Surname
Name
Region
City
Postal index

Nature of the processing

The Controller may choose to integrate the Maestra Service with advertising tools (e.g. Facebook Pixel) and merge data obtained by the tools with data stored in the Maestra Service.

Sub-processors, subject matter, nature and duration of processing

Engaged only when the Controller activates the Ad Optimization module. Operated by Albato Limited (EEA). Albato hosts Personal Data with Amazon Web Services; the onward transfer to Amazon Web Services in the United States is covered by standard contractual clauses pursuant to Commission Implementing Decision (EU) 2021/914 between Albato and Amazon Web Services. The particular advertising tool is chosen by the Controller.

16. PURPOSE: Collection of contacts from lead forms (opt-in)

Categories of personal data processed

Name
Company name
Email
Phone number
Information about the lead form where the request was left

Nature of the processing

Lead forms are posted in social media by means of the Albato tool. When an End Customer responds to a form, the history of interaction with it is sent to the Maestra Service.

Sub-processors, subject matter, nature and duration of processing

17. PURPOSE: Setting up audiences for advertising tools (opt-in)

Categories of personal data processed

Segment
Controller’s database

Nature of the processing

Defining characteristics (segments) for further marketing via advertising tools.

Sub-processors, subject matter, nature and duration of processing

Maestra Standard Integrations

18. PURPOSE: Integration with third-party services for data collection/accumulation (CMS, CRM, ERP, cashier systems, BI, apps, wallets, open APIs)

Categories of personal data processed

Controller’s database

Nature of the processing

The Controller can upload its database and integrate its databases from other services for data collection with the Maestra Service.

Sub-processors, subject matter, nature and duration of processing

The same as described for purpose 1 above.

Maestra Loyalty and Promotion Engine

19. PURPOSE: Setting up loyalty programs

Categories of personal data processed

Maestra ID (End Customer)
Information about the loyalty program

Nature of the processing

The Controller adds its End Customers to loyalty programs. The Maestra Service provides data on the history of interaction with End Customers.

Sub-processors, subject matter, nature and duration of processing

The same as described for purpose 1 above.

Maestra CDP — Analytics and Reports

20. PURPOSE: Uploading data to the Maestra Service from CSV files or via API

Categories of personal data processed

Controller’s database

Nature of the processing

The Controller can upload its database in CSV format or via API and merge it with data in the Maestra Service.

Sub-processors, subject matter, nature and duration of processing

The same as described for purpose 1 above.

21. PURPOSE: Advertising campaign analytics and report generation (conversion, advertising effectiveness measurement)

Categories of personal data processed

Pages opened
Buttons clicked
Email opening rate

Nature of the processing

The Controller may generate reports with aggregated statistics on conversion and advertising effectiveness.

Sub-processors, subject matter, nature and duration of processing

The same as described for purpose 1 above.

22. PURPOSE: Generating reports on newsletters

Categories of personal data processed

Clicks on the newsletter
Openings of the newsletter
Name of the newsletter
Newsletter campaign
Newsletter channel
Newsletter type
Tag
Brand
Conversions
Unsubscriptions
Revenue
Orders

Nature of the processing

Analysis of data on newsletter views, openings, etc., and report generation.

Sub-processors, subject matter, nature and duration of processing

The same as described for purpose 1 above.

23. PURPOSE: Generating reports on End Customers

Categories of personal data processed

Subscription status
Brand
Date of subscription
Whether End Customer is registered on the chosen channel
Average open rate
Average click rate
Orders history
Age, gender
Region
Segment
Products viewed
Product categories viewed
Information about the loyalty program

Nature of the processing

Generation of reports on particular actions and characteristics of End Customers.

Sub-processors, subject matter, nature and duration of processing

The same as described for purpose 1 above.

24. PURPOSE: Generating a report on billing actions

Categories of personal data processed

Controller’s database

Nature of the processing

View of billing metrics to verify the correctness of the invoice. The report uses key indicators such as the number of personal and End Customer actions, transitions between recalculated and static segments.

Sub-processors, subject matter, nature and duration of processing

The same as described for purpose 1 above.

25. PURPOSE: Integration of the Maestra Service with a testing environment

Categories of personal data processed

No specific categories

Nature of the processing

The Controller may simplify integration with the Maestra Service by integrating it with a testing environment.

Sub-processors, subject matter, nature and duration of processing

The same as described for purpose 1 above.

Maestra Product Recommendations

26. PURPOSE: Finding look-alike audiences in relation to the products they buy

Categories of personal data processed

Behavior of similar End Customers
History of End Customer interaction with products, newsletters, etc.

Nature of the processing

Search of End Customers with similar interests and other characteristics.

Sub-processors, subject matter, nature and duration of processing

The same as described for purpose 1 above.

II. Processings of Controller’s End Customers’ and Anonymous Customers’ Data

Maestra Next Best Action Algorithm

1. PURPOSE: Build a scenario of recommendations for products

Categories of personal data processed

Orders history
Products viewed
Product categories viewed
Actions with End Customer lists
Behavior of similar End Customers
End Customer actions with product categories
Product recommendations
History of End Customer interaction with products, newsletters, etc.
Region
Web ID
Maestra ID (End Customer)

Nature of the processing

The Controller indicates which products to recommend based on End Customer behavior.

Sub-processors, subject matter, nature and duration of processing

2. PURPOSE: Generate the next offer

Categories of personal data processed

Orders history
Products viewed
Product categories viewed
Actions with End Customer lists
Behavior of similar End Customers
End Customer actions with product categories
List of End Customers most likely to buy products (tomorrow)
Product recommendations
History of End Customer interaction with products, newsletters, etc.
Region
Web ID
Maestra ID (End Customer)

Nature of the processing

The algorithm defines the next marketing offer for an End Customer based on their behavior.

Sub-processors, subject matter, nature and duration of processing

The same as described for purpose 1 above.

3. PURPOSE: Creating a look-alike for a loyal audience

Categories of personal data processed

Segment
Information about the loyalty program

Nature of the processing

Search of potential End Customers by identifying common characteristics of End Customers subscribed to loyalty programs.

Sub-processors, subject matter, nature and duration of processing

The same as described for purpose 1 above.

III. Processings of Controller’s Admin and Authorized Users’ Data

Maestra Customer Account and Billing

1. PURPOSE: Creating an employee account in the system

Categories of personal data processed

Login
Password
Internal ID (employee)

Nature of the processing

The registration of the Controller’s profile in the Maestra Service. The Controller manages marketing activities and interaction with its End Customers using this profile.

Sub-processors, subject matter, nature and duration of processing

2. PURPOSE: Access distribution for the Controller’s employees

Categories of personal data processed

Email
Login
Access level
Internal ID (employee)

Nature of the processing

The Controller may hide personal data from certain employees.

Sub-processors, subject matter, nature and duration of processing

The same as described for purpose 1 above.

3. PURPOSE: Logging Controller logins and employee actions

Categories of personal data processed

Login
Password
Phone number
Internal ID (employee)

Nature of the processing

Sub-processors, subject matter, nature and duration of processing

The same as described for purpose 1 above.

4. PURPOSE: Authorization of user

Categories of personal data processed

Login
Password
Phone number
Internal ID (employee)

Nature of the processing

Sub-processors, subject matter, nature and duration of processing

The same as described for purpose 1 above.

C. Competent Supervisory Authority

Autoriteit Persoonsgegevens

Postbus 93374

2509 AJ DEN HAAG

Telephone: (+31) (0)70 – 888 85 00

Website: https://autoriteitpersoonsgegevens.nl/en

Annex III to the DPA — Technical and Organisational Measures

The Processor has implemented and maintains the following technical and organisational measures to ensure the security of Personal Data:

Access control policy is implemented
Employee training on data protection and information security
Monitoring the composition of hardware, software, and information security tools
Rules for using email and spam protection
Information security risk analysis is conducted annually
Information security policy is implemented
Differentiation of access rights
A registry of information assets is maintained
Inventory of information assets is carried out annually
Risk management policy
Areas of responsibility for information security are defined and distributed
Information security provisions are included in contracts with counterparties
Mobile device management tool combined with anti-virus software and enforced updates
Non-disclosure agreements with employees are signed
Employees have access to training material on information security
Non-disclosure agreements with counterparties are signed
When an employee leaves, they must complete information-security off-boarding steps set out in a documented checklist
System of accounting of hardware in the infrastructure
Confidentiality policy
Network segmentation
Accounting and reporting of operating systems on workstations and servers
Security logs are collected and analyzed centrally
Personal Data in the product is masked
Protection against brute-force attacks during password entry (blocking after 5 failed attempts)
Two-factor authentication
Password management tools are used to ensure password security
CCTV at the entrance to the company’s office
Equipment is sited as recommended by respective manufacturers and security regulations
Clean desk policy
Clean screen policy
Lock screen policy
Endpoint protection (Microsoft Defender or equivalent) is installed on all workstations
Master data management tools are implemented
Daily data backup
Additional off-site backup storage is in place
Log of information security incidents
Logging of user workstations is carried out by built-in operating system means
Users’ and administrators’ activities in the information system are logged by the built-in tools of the operating system and the information system
External web application scanning for vulnerabilities
Network equipment supports firewall features
Testing of new versions of information systems in an isolated environment
Network management and control is performed by enterprise-grade firewalls
Access Control Lists (ACLs) are configured between VLANs
Rules are set up to filter incoming traffic; all unused ports are blocked
Recommended data transfer channels are given in the product instruction
Application sessions are protected with tokens
Sessions are protected with unique link-signed keys sent by email and other means
License agreements are signed with counterparties
Journal of familiarisation with the rules of processing personal data is maintained for employees
Formalised list of positions allowed to process personal data
External information security audits
Logins and exits to the admin account are logged
Granting of accesses is logged
The administrator can differentiate access rules for personnel
The Controller can view the actions of a support employee in the action log
Personal data are masked for Processor employees
The Controller can set retention period for storing personal data
Backups of deleted data are stored for 6 months
The Controller can set the password expiration date
The Controller can choose to mask personal data in the accounts of its particular employees
Data encryption type is chosen by the Controller in their account
SOC 2 Type II certified controls (further detailed in Exhibit C (EU))

— End of Annex I (EU) —