Data Processing Addendum (DPA)

Version 1.0 · 2026

This Data Protection Addendum (“Addendum”) between Parsio Software SAS (“Parsio”) and the Customer (as defined in the Agreement) forms part of the Parsio Software SAS Terms of Service set forth at https://www.parsio.ai/mentions-legales or such other written or electronic agreement incorporating this Addendum, in each case governing Customer’s access to and use of the Services (the “Agreement”).

Customer enters into this Addendum on behalf of itself and any Affiliates authorized to use the Services under the Agreement and who have not entered into a separate contractual arrangement with Parsio. For the purposes of this Addendum only, and except where otherwise indicated, references to “Customer” shall include Customer and such Affiliates.

The Parties hereby agree that the terms and conditions set out below shall be added as an Addendum to the Agreement.

1. Definitions

In this Addendum, the following terms shall have the meanings set out below and cognate terms shall be construed accordingly:

• “Affiliate” means an entity that owns or controls, is owned or controlled by, or is under common control or ownership with either Customer or Parsio (as the context allows), where control is defined as the possession, directly or indirectly, of the power to direct or cause the direction of the management and policies of an entity, whether through ownership of voting securities, by contract or otherwise;
• “Customer Personal Data” means any Personal Data provided by or made available by Customer to Parsio, or collected by Parsio on behalf of Customer, which is Processed by Parsio to perform the Services;
• “Controller to Processor SCCs” means the standard contractual clauses for cross-border transfers published by the European Commission on June 4, 2021 governing the transfer of European Area Personal Data to Third Countries as adopted by the European Commission, the Swiss Federal Data Protection and Information Commissioner (“Swiss FDPIC”) relating to data transfers to Third Countries (collectively “EU SCCs”); (ii) the international data transfer addendum (“UK Transfer Addendum”) adopted by the UK Information Commissioner’s Office (“UK ICO”) for data transfers from the UK to Third Countries; or (iii) any similar such clauses adopted by a data protection regulator relating to Personal Data transfers to Third Countries, including without limitation any successor clauses thereto;
• “Data Protection Laws” means any local, state, or national law regarding the processing of Personal Data applicable to Parsio in the jurisdictions in which the Services are provided to Customer, including, without limitation, privacy, security, and data protection law; they include GDPR (Regulation (EU) 2016/679) and the French Data Protection Act (Loi n° 78-17 du 6 janvier 1978), as amended;
• “EU Area” means the European Union, European Economic Area, United Kingdom, and Switzerland;
• “EU Area Law” means (i) Directive 95/46/EC and, from May 25, 2018, Regulation (EU) 2016/679 (“EU GDPR”) together with applicable legislation implementing or supplementing the same or otherwise relating to the processing of Personal Data of natural persons; (ii) the Data Protection Act 1998 of the United Kingdom and the EU GDPR as saved into United Kingdom Law by virtue of section 3 of the United Kingdom’s European Union (Withdrawal) Act 2018 (the “UK GDPR”); (iii) the Swiss Federal Data Protection Act of 19 June 1992 and its Ordinance (“Swiss DPA”); (iv) any other law relating to the data protection, security, or privacy of individuals that applies in the EU Area; or (v) any successor or amendments thereto;
• “Security Incident” means any breach of security that leads to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Customer Personal Data being Processed by Parsio;
• “Services” means the services to be supplied by Parsio to Customer or Customer’s Affiliates pursuant to the Agreement; and
• “Third Country” means countries that, where required by applicable Data Protection Laws, have not received an adequacy decision from an applicable authority relating to cross-border data transfers of Personal Data, including regulators such as the European Commission, UK ICO, or Swiss FDPIC.

The terms “Business”, “Business Purpose”, “commercial purpose”, “Contractor”, “Controller”, “Data Subject”, “Personal Data”, “Personal Data Breach”, “Process”, “Processor”, “Sell”, “Service Provider”, “Share”, “Subprocessor”, “Supervisory Authority”, and “Third Party” have the same meanings as described in applicable Data Protection Laws, and cognate terms shall be construed accordingly. Capitalized terms not otherwise defined in this Addendum shall have the meanings ascribed to them in the Agreement.

2. Scope of Addendum

This Addendum applies to Parsio’s Processing of Customer Personal Data under the Agreement to the extent such Processing is subject to Data Protection Laws. This Addendum is governed by the governing law of the Agreement unless otherwise required by Data Protection Laws.

3. Roles of the Parties

The Parties acknowledge and agree that with regard to the Processing of Customer Personal Data, and as more fully described in Annex 1 hereto, Customer acts as a Business or Controller, and Parsio acts as a Service Provider or Processor. This Addendum shall apply solely to the Processing of Customer Personal Data by Parsio acting as a Processor, Subprocessor, or Third Party (as specified in Annex 1).

The Parties expressly agree that Customer shall be solely responsible for ensuring timely communications to Customer’s Affiliates or the relevant Controller(s) who receive the Services, insofar as such communications may be required or useful in light of applicable Data Protection Laws to enable them to comply with such Laws.

Customer is solely responsible for complying with Security Incident notification laws applicable to Customer and fulfilling any obligations to give notices to government authorities, affected individuals, or others relating to any Security Incidents.

4. Description and Purpose of Personal Data Processing

In Annex 1 to this Addendum, the Parties have mutually set out their understanding of the subject matter and details of the Processing of the Customer Personal Data to be Processed by Parsio pursuant to this Addendum. The Parties may make reasonable amendments to Annex 1 on mutual written agreement and as reasonably necessary to meet those requirements or to address the requirements of Data Protection Laws from time to time. Annex 1 does not create any obligation or rights for any Party.

The purpose of Processing under this Addendum is the provision of the Services pursuant to the Agreement and any Order Form(s).

5. Data Processing Terms

Customer shall comply with all applicable Data Protection Laws in connection with the performance of this Addendum and the Processing of Customer Personal Data. In connection with its access to and use of the Services, Customer shall Process Customer Personal Data within such Services and provide Parsio with instructions in accordance with applicable Data Protection Laws. As between the Parties, Customer shall be solely responsible for compliance with applicable Data Protection Laws regarding the collection of and transfer to Parsio of Customer Personal Data. Customer agrees not to provide Parsio with any data concerning a natural person’s health, religion, or any special categories of data as defined in Article 9 of the GDPR.

Parsio shall comply with all applicable Data Protection Laws in the Processing of Customer Personal Data and Parsio shall:

(a) Process the Customer Personal Data for the purposes of the Agreement and for the specific purposes set out in Annex 1 to this Addendum and otherwise solely on the documented instructions of Customer, for the purposes of providing the Services and as otherwise necessary to perform its obligations under the Agreement. The Agreement, this Addendum, and Customer’s use of the Services’ features and functionality are Customer’s written instructions to Parsio in relation to Processing Customer Personal Data, including as follows:

• Parsio shall use, retain, disclose, or otherwise Process Customer Personal Data only on behalf of Customer and for the specific business purpose of providing the Services and in accordance with Customer’s instructions, including as described in the Agreement. Parsio shall not Sell or Share Customer Personal Data, nor use, retain, disclose, or otherwise Process Customer Personal Data outside of its business relationship with Customer or for any other purpose (including Parsio’s commercial purpose) except as required or permitted by law. Parsio shall immediately inform Customer (a) if Parsio determines that it is no longer able to meet its obligations under Data Protection Laws or (b) if, in Parsio’s opinion, an instruction infringes applicable Data Protection Laws. Customer reserves the right to take reasonable and appropriate steps to ensure Parsio’s Processing of Customer Personal Data is consistent with Customer’s obligations under Data Protection Law and to discontinue and remediate unauthorized use of Customer Personal Data;
• Parsio shall have rights to process Customer Personal Data solely (i) to the extent necessary to (a) perform the Business Purposes and its obligations under the Agreement; (b) operate, manage, test, maintain, and enhance the Services including as part of its business operations; (c) disclose aggregate statistics about the Services in a manner that prevents individual identification or re-identification of Customer Personal Data; and/or (d) protect the Services from a threat to the Services or Customer Personal Data; or (ii) if required by court order of a court or authorized governmental agency, provided that prior notice first be given to Customer; (iii) as otherwise expressly authorized by Customer;
• Parsio will not combine Customer Personal Data which Parsio Processes on Customer’s behalf with Personal Data which it receives from or on behalf of another person, or collects from its own interaction with individuals, provided that Parsio may combine personal information to perform any Business Purpose permitted or required under the Agreement to perform the Services;

(b) implement and maintain measures designed to ensure that Parsio personnel authorized to process the Customer Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality unless disclosure is required by law or professional regulations;

(c) implement and maintain the technical and organizational measures set out in the Agreement, and, 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 natural persons, implement and maintain any further commercially reasonable and appropriate administrative, technical, and organizational measures designed to ensure a level of security appropriate to the risk of the Processing of Customer Personal Data in accordance with Article 32 of the GDPR, and specifically:

• pseudonymization and encryption of Customer Personal Data;
• ensuring ongoing confidentiality, integrity, availability, and resilience of Parsio’s processing systems and services that process Customer Personal Data;
• restoring availability and access to Customer Personal Data in a timely manner in the event of a physical or technical incident; and
• regularly testing, assessing, and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing of the Customer Personal Data.

(d) Customer hereby agrees that Parsio is generally authorized to engage and appoint Sub-processors, and specifically the Sub-processors listed in Annex 2 hereto, subject to Parsio’s:

• including data protection obligations in its contract with each Sub-processor that are materially the same as those set out in this Addendum; and
• remaining liable to Customer for any failure by each Sub-processor to fulfill its obligations in relation to the Processing of the Customer Personal Data;
• giving Customer notice of the addition or replacement of any Sub-processor by maintaining and updating the Sub-processor list at Annex 2 (as published by Parsio). Customer may object on reasonable data-protection grounds within 30 days of the update; if unresolved in good faith, Customer’s sole remedy is to terminate the affected portion of the Services. Use of a Sub-processor is not conditional on Customer’s prior approval.

(e) to the extent legally permissible, promptly notify Customer in case of any legally binding requests (i.e., disclosures required by law, court order, or subpoena) for disclosure of Customer Personal Data by Parsio. If the request is not legally binding, Customer Personal Data will not be disclosed and Parsio will notify the Customer of such request rejection. A record of all legally binding disclosure requests relating to Customer Personal Data shall be maintained.

(f) to the extent legally permissible, promptly notify Customer of any communication from a Data Subject regarding the Processing of Customer Personal Data, or any other communication (including from a Supervisory Authority) relating to any obligation under the applicable Data Protection Laws in respect of the Customer Personal Data. Parsio will not respond to any such request or complaint unless expressly authorized to do so by Customer or otherwise required to respond under applicable Data Protection Laws. Taking into account the nature of the Processing, Parsio will reasonably assist Customer (or the relevant Controller) by appropriate technical and organizational measures, insofar as this is possible, for the fulfillment of the obligation to respond to requests for exercising the data subject’s rights laid down in Chapter III GDPR. Customer agrees to pay Parsio for time and for out-of-pocket expenses incurred in connection with the performance of its obligations under this Section.

(g) upon becoming aware of a Personal Data Breach involving Customer Personal Data, notify Customer without undue delay, such notice to include, to the extent reasonably available to Parsio, all timely information reasonably required by Customer (or the relevant Controller) to comply with its data breach reporting obligations under the applicable Data Protection Laws. Parsio shall further take all such measures and actions as are necessary to remedy or mitigate the effects of such Security Incident and shall keep Customer reasonably informed of developments. Customer acknowledges that Parsio’s notification of a Security Incident is not an acknowledgement by Parsio of its fault or liability. Security Incidents do not include unsuccessful attempts or activities that do not compromise the security of Customer Personal Data, including unsuccessful login attempts, pings, port scans, denial of service attacks, or other network attacks on firewalls or networked systems;

(h) to the extent required by the applicable Data Protection Laws, provide reasonable assistance to Customer with its obligations pursuant to Articles 32 to 36 of the GDPR taking into account the nature of the Processing and information available to Parsio; Customer agrees to pay Parsio for time and out-of-pocket expenses incurred in connection with any assistance provided in connection with Articles 35 and 36 of the GDPR;

(i) cease Processing the Customer Personal Data upon the termination or expiry of the Agreement, and at the option of Customer either return or delete (including by ensuring such data is in non-readable format) all copies of the Customer Personal Data Processed by Parsio, unless (and solely to the extent and for such period as) applicable law requires Parsio to retain some or all of the Customer Personal Data. Any such retained Customer Personal Data shall remain subject to the obligations of confidentiality set forth in the Agreement;

(j) maintain the necessary records in support of demonstrating compliance with its obligations for the processing of Customer Personal Data carried out on behalf of the Customer; and

(k) make available to Customer all information reasonably necessary to demonstrate compliance with this Addendum and allow for and contribute to audits, including inspections, by Customer or an independent third-party auditor mandated by Customer, provided that Customer gives Parsio reasonable prior notice, conducts its audit during Parsio’s normal business hours, and takes all reasonable measures to prevent unnecessary disruption to Parsio’s operations. The Parties agree that, in the first instance, once per year during the term of the Agreement (except where required by a competent Supervisory Authority or where Customer believes a further audit is necessary due to a Personal Data Breach), Parsio will provide responses to cybersecurity and other assessments, and only where Customer cannot establish Parsio’s compliance from such responses shall Customer request to inspect Parsio’s processing operations. Customer agrees to pay Parsio for time and out-of-pocket expenses incurred in connection with such audits and assessments.

6. Warranties

The Parties warrant that they and any staff and/or subcontractors will comply with their respective obligations under Data Protection Laws for the term.

7. Restricted Transfers

The Parties agree that when the transfer of Customer Personal Data from Customer and/or any of its Affiliates (as exporter) to Parsio (as importer) is a Restricted Transfer and EU Area Law applies, the transfer shall be subject to the appropriate Controller to Processor SCCs, which shall be deemed incorporated into and form part of this Addendum as follows:

(a) In relation to Customer Personal Data that is protected by the EU GDPR and processed by Parsio on behalf of and under the instruction of Customer, the EU SCCs will apply completed as follows:

• Module Two will apply (controller to processor transfers);
• In Clause 7, the optional docking clause will apply;
• In Clause 9, Option 2 will apply, and the time period for prior notice of sub-processor changes shall be as set out in Section 5(d) of this Addendum;
• In Clause 11, the optional language will not apply;
• In Clause 17, Option 1 will apply, and the EU SCCs will be governed by French law;
• In Clause 18(b), disputes shall be resolved before the courts of Rennes, France;
• Annex I of the EU SCCs shall be deemed completed with the information set out in Annex 1 to this Addendum; and
• Annex II of the EU SCCs shall be deemed completed with the information set out in Section 4 of Annex 1 to this Addendum.

(b) In relation to Customer Personal Data that is protected by the Swiss DPA, the EU SCCs shall apply in accordance with Section 7(a) of this Addendum, but with the following modifications: references to “Regulation (EU) 2016/679” shall be interpreted as references to the Swiss DPA; references to “EU”, “Union”, “Member State”, and “Member State law” shall be interpreted as references to Switzerland and Swiss law; references to the “competent supervisory authority” and “competent courts” shall be interpreted as references to the relevant data protection authority and courts in Switzerland; and the SCCs shall be governed by the laws of Switzerland and disputes resolved before the competent Swiss courts.

(c) In relation to Customer Personal Data that is protected by the UK GDPR, the EU SCCs shall apply in accordance with Section 7(a) of this Addendum, but as modified and interpreted by the Part 2: Mandatory Clauses of the UK Addendum, which shall be incorporated into and form an integral part of this Addendum.

(d) Parsio shall process Personal Data using AI and machine learning technologies, in accordance with the terms of this Addendum and applicable Data Protection Laws, including the GDPR. The purpose of such AI processing is limited to providing the Services. Parsio shall ensure that any AI processing of Personal Data is conducted only to the extent necessary to achieve the specified purposes. Notwithstanding any right to enhance the Services, Customer Personal Data will not be used to train, fine-tune, or improve any AI or machine-learning models, whether operated by Parsio or by any Sub-processor.

Parsio shall not participate in any other Restricted Transfers of Customer Personal Data unless the Restricted Transfer is made in compliance with applicable Data Protection Law and pursuant to the relevant Standard Contractual Clauses implemented between the relevant exporter and importer.

Transfer mechanism. Where a party is located outside the EEA or an adequate country and receives Personal Data: (a) that party will act as the data importer, (b) the other party is the data exporter, and (c) the relevant Transfer Mechanism will apply. Additional measures. If the Transfer Mechanism is insufficient to safeguard the transferred Personal Data, the data importer will promptly implement supplementary measures. Disclosures. Subject to the relevant Transfer Mechanism, if the data importer receives a request from a public authority to access Personal Data, it will (if legally allowed) challenge the request, promptly notify the data exporter, and disclose only the minimum amount of Personal Data required, keeping a record of the disclosure.

8. Precedence

The provisions of this Addendum are supplemental to the provisions of the Agreement. In the event of any inconsistency, they will take priority in this order: (a) any Standard Contractual Clauses or other Cross-Border Transfer Mechanisms, (b) this Addendum, (c) the Agreement. In the event any provision of this Addendum and/or the Agreement contradicts, directly or indirectly, the Controller to Processor SCCs, the Controller to Processor SCCs will control.

9. Indemnity

To the extent permissible by law, Customer shall (a) defend Parsio and its Affiliates (collectively, “Indemnified Parties”) from and against any and all claims, demands, suits, or proceedings made or brought against any of the Indemnified Parties by any third party (each, a “Claim”), and (b) indemnify and hold harmless the Indemnified Parties from and against any and all losses, damages, liabilities, fines and administrative fines, penalties, settlements, and costs and expenses of any kind (including reasonable legal, investigatory, and consultancy fees) incurred or suffered by any of the Indemnified Parties, in each case arising from any breach by Customer of this Addendum or of its obligations under applicable Data Protection Laws. Parsio may participate in the defense and/or settlement of a Claim with counsel of its choosing at its own expense.

10. Severability

The Parties agree that, if any section or sub-section of this Addendum is held by any court or competent authority to be unlawful or unenforceable, it shall not invalidate or render unenforceable any other section of this Addendum.

11. Miscellaneous

The Addendum considers and follows: Privacy by Design and default; achieving security of Processing; notification of breaches involving Customer Personal Data to the relevant Supervisory Authority; notification of breaches to Customer; conducting a Data Protection Impact Assessment (DPIA) where appropriate and required by applicable Data Protection Law; and assurance of Parsio’s assistance where prior consultations with relevant Supervisory Authorities are needed and required by applicable Data Protection Laws.

Parsio complies with applicable statutory and regulatory requirements and processes personal data in accordance with applicable GDPR requirements.

In the event a Data Subject wishes to exercise its data subject rights under applicable Data Protection Law, including the right of access, correction, and/or erasure of its Personal Data in Parsio’s control, the Data Subject can submit such request by contacting Parsio’s Privacy contact below. For raising concerns and/or complaints related to Customer Personal Data, contact Parsio’s Privacy contact, Xavier, at xavier@parsio.ai.

Annex 1. Description of Processing Activities

This Annex includes certain details of the Processing of Customer Personal Data by Parsio in connection with the Services.

A. List of Parties

Data Exporter

Data Importer

B. Competent Supervisory Authority

C. Processing Information

D. Technical and Organisational Security Measures

Security Management System, Parsio designates qualified security personnel responsible for the development, implementation, and ongoing maintenance of its Information Security Program. Management reviews and supports all security-related policies, updated at least once annually. Parsio maintains a risk treatment program including vulnerability management and patch management.

Personnel Security, Personnel conduct themselves consistently with confidentiality, business ethics, and professional standards. Personnel execute a confidentiality agreement at the time of hire and receive privacy and security training. Parsio’s personnel will not process Customer Personal Data without authorization.

Access Controls, Parsio maintains a formal access management process for the request, review, approval, and provisioning of personnel access to Customer Personal Data, based on principles of “least privilege” and “need to know”. Administrators and end users authenticate via multi-factor authentication or single sign-on. Access to systems is logged to create an audit trail.

Data Centre and Network Security, Parsio hosts the Services on established cloud infrastructure providers, with data hosted within the European Union. Multiple Availability Zones are enabled, and backups are tested regularly. HTTPS (SSL/TLS) is used for data in transit and encryption is implemented for data at rest. Parsio performs regular vulnerability scans and maintains incident management policies and procedures.

Data Storage, Isolation, Authentication, and Destruction, Parsio logically isolates the data of different customers in a multi-tenant environment, uses a central authentication system, and ensures secure disposal of Customer Data through a series of data destruction processes.

Annex 2. Parsio’s Sub-processors

Parsio engages a limited number of sub-processors to provide the Services. They are engaged by category of activity as set out below. The current, detailed list of sub-processors (including names and locations) is available to Customer on request and is updated in accordance with Section 5(d) of this Addendum.

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