Data Processing Addendum

1. Roles and instructions

Customer is the Controller (or Processor where it provides services to another Controller), and Seatext is the Processor or Subprocessor as applicable. Seatext Processes Customer Personal Data only on Customer’s documented instructions, including the agreement, this DPA, Customer’s configuration and authorized use of the Services, and other written instructions accepted by Seatext, unless Processing is required by law.

Seatext will notify Customer if an instruction appears to violate applicable data-protection law, unless law prohibits notice.

2. Confidentiality and security

Seatext limits access to personnel and Subprocessors who need it to provide the Services and who are subject to confidentiality obligations. Seatext maintains reasonable administrative, technical, and organizational measures designed to protect Customer Personal Data against unauthorized or unlawful Processing and accidental loss, destruction, alteration, or disclosure.

3. Personal Data Breaches

Seatext will notify Customer without undue delay after becoming aware of a confirmed Personal Data Breach affecting Customer Personal Data and, where feasible, within 48 hours. Seatext will provide available information about the incident, containment and remediation measures, and reasonably assist Customer with legally required notifications. Customer is responsible for deciding whether to notify authorities or Data Subjects unless law places that duty directly on Seatext.

4. Subprocessors

Customer gives Seatext general written authorization to use Subprocessors. Seatext will maintain an accurate list and provide at least 30 days’ notice before a new Subprocessor begins Processing Customer Personal Data. Customer may object within 15 days on reasonable data-protection grounds. If the Parties cannot resolve a valid objection, Customer may terminate only the affected Services before the new Subprocessor begins Processing.

Seatext will bind Subprocessors to data-protection obligations no less protective in substance than those in this DPA and remains responsible for their performance subject to the agreement’s liability terms.

5. Assistance, audits, and deletion

Taking account of the nature of Processing, Seatext will reasonably assist Customer with Data Subject requests, data-protection impact assessments, transfer assessments, and regulator inquiries. On reasonable written request, Seatext will provide information needed to demonstrate compliance. If that information is insufficient, Customer may conduct one reasonable audit per 12-month period with advance notice, subject to confidentiality, security, and non-disruption safeguards.

During the term, Customer may export Customer Personal Data through available functionality or a reasonable written request. After termination, Seatext will return or delete Customer Personal Data within 60 days at Customer’s written choice, unless retention is required by law. Backup copies remain protected and are deleted or overwritten in Seatext’s normal backup lifecycle.

6. International transfers and U.S. privacy terms

Seatext may Process Customer Personal Data in the United States and other countries where Seatext and its Subprocessors operate. Where required, the Parties incorporate the EU Standard Contractual Clauses (Module Two for Controller-to-Processor transfers and Module Three for Processor-to-Processor transfers) and the UK Addendum. For U.S. state privacy laws, Seatext acts as a Service Provider, Contractor, Processor, or analogous recipient and will not sell or share Customer Personal Data, use it outside the documented business purposes, or combine it with other personal information except as permitted by applicable law.

7. Details of Processing

Services and purposes. Seatext provides website personalization, translation, A/B testing, analytics, bot detection, invalid-click reporting, chat, AI content, integrations, support, security, and related marketing features. Processing may include collection, transmission, storage, retrieval, analysis, classification, generation, display, reporting, and deletion to operate and improve the enabled Services for Customer.

Data Subjects. Customer’s website and application visitors, prospects, customers, chat or form users, Customer personnel, and other individuals whose data Customer provides through an enabled integration.

Personal Data. This can include IP and network information; cookie and pseudonymous identifiers; browser, device, language, time-zone, and approximate location data; URLs, referrers, campaign data, page views, clicks, scrolls, interaction events, conversion and experiment data, bot and fraud signals; website text and submitted content; and, where enabled, names, business contact data, chat content, lead data, CRM attributes, support data, and conversion values. Customer must not submit special-category or sensitive data unless the Parties expressly agree in writing on appropriate safeguards.

Annex III — current Subprocessors

MongoDB, Inc. — database hosting and storage for service data.

Google LLC (Google Gemini). — LLM processing for enabled AI features. Customer data is sent only as needed to provide the requested enabled feature.

Seatext may use additional Subprocessors as described in Section 4. For customer-specific questions about this DPA, Subprocessors, security, deletion, or privacy rights, contact [email protected].