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AccuReach LLC

Customer Contract Claus

AccuReach Services use industry-accepted encryption practices to protect Customer Data and communications during transmissions between a Customer's network and the AccuReach Services, including 256-bit TLS Certificates and 4096-bit RSA public keys at a minimum. AccuReach audits the TLS ciphers used in connection with the provision of the AccuReach Services with third-party security auditors to ensure that anonymous or weak ciphers are not used. These audits also confirm that the AccuReach Services do not allow client renegotiation, support downgrade attack protection and forward secrecy. Data shipped to Customer is encrypted in transit and at-rest using AES-256 encryption via our proprietary managed encryption key process. Where use of the AccuReach Services requires a customer to provide access to third party services (for example, AWS S3 credentials for data exports), AccuReach performs additional encryption of that information.

1.Personal Data Processing.

i.Details of Processing. The parties acknowledge and agree that with regard to the Processing of Personal Data, Customer is the Controller, AccuReach is the Processor and that AccuReach or its Affiliates engaged in the Processing of Personal Data may engage Sub-processors pursuant to the requirements set forth in [the applicable section of the Contract with the Customer]. The Processing of Personal Data by AccuReach is the performance of the AccuReach Services pursuant to the Customer Agreement. The duration of the Processing, the nature and purpose of the Processing, the types of Personal Data and categories of Data Subjects Processed pursuant to the Customer Agreement are further specified in the applicable Schedule annexed to and made part of the Customer Agreement. The parties shall exercise their rights hereunder acting in good faith and in a reasonable manner.


ii.Customer’s Processing of Personal Data. Customer shall, in its use of the AccuReach Services, Process Personal Data in accordance with the requirements of applicable Data Protection Laws and Regulations. Customer’s instructions for the Processing of Personal Data shall comply with Data Protection Laws and Regulations applicable to the jurisdiction(s) in which the Customer conducts its own business. Upon entering into the Customer Agreement and any applicable Order Form(s), the Personal Data Processing Details contained herein shall be considered by the parties as Customer’s documented instructions to AccuReach for the Processing of Personal Data. Any additional or alternate instructions must be reasonable and consistent with the terms of the Customer Agreement. Customer shall have sole responsibility for the accuracy, quality, and legality of Personal Data and the means by which Customer acquired the Personal Data.


iii.AccuReach’s Processing of Personal Data. AccuReach shall only Process Personal Data in accordance with Customer’s documented instructions pursuant to Section 1.2 above, and for the following purposes: (i) Processing in accordance with the Agreement, applicable Order Form(s) and Data Protection Laws and Regulations; and (ii) Processing initiated by Customer Users in their use of the AccuReach Services (collectively the (“Business Purpose”). AccuReach shall not Process Personal Data for any purpose other than the Business Purpose or outside of the direct business relationship with Customer. AccuReach shall, in its provision of the AccuReach Services, Process Personal Data in accordance with Data Protection Laws and Regulations, provided that AccuReach shall not be in violation of this contractual obligation in the event that AccuReach's Processing of Personal Data renders AccuReach to be non-compliant with Data Protection Laws and Regulations, where such non-compliance arises from Customer’s use of the AccuReach Services in violation of the Agreement. AccuReach shall not Sell or Share Personal Data.