Data Processing Agreement (DPA)

Effective Date: August 20, 2025
Last Updated: August 20, 2025

Agreement Formation and Acceptance

This Tamio GmbH Data Processing Agreement ("DPA") becomes effective on August 20, 2025, and applies to all customers who accept our Terms of Use on or after this date. By clicking "I Accept" or similar acceptance mechanism during signup, you are agreeing to be bound by this DPA, which incorporates the Standard Contractual Clauses adopted by the European Commission.

This DPA forms part of and is incorporated into the Tamio GmbH Terms of Use ("Agreement"). The DPA shall remain in effect for the duration of the Agreement.

No Physical Signatures Required: This DPA is legally binding upon your electronic acceptance during registration. No handwritten or physical signatures are required for this agreement to be valid and enforceable.

Purpose and Scope

The purpose of this DPA is to secure adequate safeguards with respect to the protection of privacy and to ensure that the processing of Personal Data is in accordance with the Data Controller's and Data Processor's legal obligations under applicable data protection laws.

THIS DPA INCLUDES:

Standard Contractual Clauses, attached hereto as EXHIBIT 1
Appendix 1 to the Standard Contractual Clauses (data transfer specifics)
Appendix 2 to the Standard Contractual Clauses (technical and organizational security measures)
List of Sub-Processors, attached hereto as EXHIBIT 2

Definitions

"Controller" means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the Processing of Personal Data.

"Data Protection Law" means all applicable legislation relating to data protection and privacy including without limitation the GDPR, together with any national implementing laws in any Member State of the European Union or other applicable jurisdictions.

"Data Subject" means the individual to whom Personal Data relates.

"GDPR" means the General Data Protection Regulation (EU) 2016/679.

"Instruction" means the documented instruction, issued by Controller to Processor, directing the same to perform a specific action with regard to Personal Data.

"Personal Data" means any information relating to an identified or identifiable individual where such information is contained within Customer Data and is protected as personal data under applicable Data Protection Law.

"Personal Data Breach" means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Data.

"Processing" means any operation performed on Personal Data, including collection, recording, organization, structuring, storage, adaptation, retrieval, consultation, use, disclosure, alignment, restriction, or erasure.

"Processor" means a natural or legal person which processes Personal Data on behalf of the Controller.

"Standard Contractual Clauses" means the clauses attached as Exhibit 1 pursuant to European Commission decisions for adequate data protection safeguards.

Details of Processing

Categories of Data Subjects: Customer's contacts and end users including employees, contractors, collaborators, customers, prospects, suppliers and subcontractors. Data Subjects also include individuals attempting to communicate with or transfer Personal Data to the Customer's end users.

Types of Personal Data: Contact information, navigational data, email data, system usage data, application integration data, and other electronic data submitted, stored, sent, or received via our services.

Subject-Matter and Nature of Processing: Provision of ecommerce platform services that involve Processing of Personal Data as specified in the Agreement.

Purpose of Processing: Personal Data will be Processed to provide the services outlined in the Agreement.

Duration of Processing: For the duration of the Agreement, subject to data retention and deletion provisions below.

Customer Responsibilities

You, as Controller, are solely responsible for:

Complying with all applicable data protection requirements
Ensuring lawful disclosure and transfer of Personal Data to us
Providing lawful instructions for Processing
Informing us of any errors or irregularities related to data protection requirements

Your instructions for Processing Personal Data must comply with Data Protection Law. This DPA constitutes your complete instruction to Tamio GmbH regarding Personal Data processing. Additional instructions require written agreement between the parties.

Our Obligations as Processor

Compliance with Instructions

We will process Personal Data only within the scope of your instructions. If we believe an instruction violates Data Protection Law, we will immediately inform you. If we cannot process Personal Data according to instructions due to legal requirements, we will:

Promptly notify you of the legal requirement (where permitted)
Cease processing until you provide compliant instructions

Security Measures

We implement appropriate technical and organizational measures to protect Personal Data against unauthorized access, alteration, disclosure, or destruction, including:

Physical access controls to processing systems
Logical access controls preventing unauthorized system use
Data access controls ensuring authorized personnel access only necessary data
Data transfer controls for secure transmission and storage
Entry controls documenting data system access and modifications
Instruction controls ensuring processing only per your instructions
Availability controls protecting against accidental destruction or loss

We will provide details of our current security program upon your request and facilitate your compliance with security obligations under Articles 32-34 of the GDPR.

Confidentiality

All personnel authorized to process Personal Data are subject to confidentiality obligations that survive termination of their activities.

AI and Automated Processing

If our services include any artificial intelligence or automated decision-making features that process Personal Data, we will:

Provide clear information about the logic involved
Inform you of the significance and envisaged consequences
Implement appropriate safeguards for data subjects' rights
Ensure human oversight where required by applicable law

Data Localization and Residency

We maintain Personal Data in accordance with any applicable data localization requirements. Upon request, we can provide information about where your Personal Data is stored and processed.

Breach Notification Timeline

We will notify you of any Personal Data Breach:

Without undue delay, and where feasible within 24 hours of becoming aware
With all available information at the time of notification
With follow-up information as it becomes available

Data Subject Requests

We will provide reasonable assistance to enable you to respond to Data Subject requests to exercise their rights under Data Protection Law. If requests are made directly to us, we will promptly inform you and direct the Data Subject to contact you. You are solely responsible for responding to Data Subject requests and will reimburse us for costs arising from such assistance.

Sub-Processors

We may engage sub-processors to fulfill our obligations only with your consent. You consent to our engagement of affiliated companies and third parties listed in Exhibit 2.

For new sub-processors not listed in Exhibit 2, we will:

Provide written notice (email to your account address is sufficient)
Give you 30 days to object on reasonable grounds
If objections cannot be resolved, either party may terminate the Agreement with written notice

All sub-processors must agree to the same data protection obligations that apply to us. We remain liable for sub-processor performance of these obligations.

International Data Transfers

Personal Data may be transferred to Tamio GmbH in Germany and to sub-processors in various locations. We ensure appropriate safeguards are in place for all transfers outside the EEA through:

Standard Contractual Clauses (current 2021 version, will update to 2025 version when available)
Adequacy decisions where applicable
Other approved transfer mechanisms under Chapter V GDPR
Regular transfer impact assessments (TIAs) as required

We monitor regulatory developments regarding international transfers and will implement any additional safeguards required by supervisory authorities.

Data Retention and Deletion

Upon termination or expiry of the Agreement, we will delete all Personal Data unless required to retain it by law. If deletion is not possible for technical reasons, we will block the data from further processing. You may request specific return or deletion procedures by providing instructions within our specified timeframe. Additional costs for data return or deletion after termination will be borne by you.

Audits

You may audit our technical and organizational measures by:

Requesting information from us
Requesting existing certifications or attestations
Conducting on-site inspections during business hours with reasonable advance notice

We will provide necessary audit information within our control and not precluded by law or confidentiality obligations.

General Provisions

Amendments: This DPA may be updated according to the amendment provisions in our Terms of Use. We will provide notice of material changes.

Precedence: In case of conflict, this DPA takes precedence over the general Agreement terms. If any provision is invalid, other provisions remain enforceable.

Standard Contractual Clauses: Where applicable, the Standard Contractual Clauses in Exhibit 1 prevail over any conflicting DPA terms. The European Commission plans to update SCCs in 2025, and we will incorporate any required updates.

Effective Date: This DPA incorporates current GDPR requirements and will be updated to reflect any new regulatory requirements.

Parties and Authority

By accepting this DPA during registration:

You represent that you are authorized to agree to this DPA on behalf of your organization
You are agreeing solely on behalf of the Controller entity
Both you and Tamio GmbH become parties to this DPA and the incorporated Standard Contractual Clauses

EXHIBIT 1: Standard Contractual Clauses (Processors)

For the purposes of Article 26(2) of Directive 95/46/EC for the transfer of personal data to processors established in third countries which do not ensure an adequate level of data protection,

The Customer (the "data exporter")
Tamio GmbH (the "data importer")

HAVE AGREED on the following Contractual Clauses to adduce adequate safeguards for the transfer of personal data specified in Appendix 1.

Clause 1: Definitions

For the purposes of the Clauses:

‘personal data’, ‘special categories of data’, ‘process/processing’, ‘controller’, ‘processor’, ‘data subject’ and ‘supervisory authority’ shall have the same meaning as in Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 on the protection of individuals with regard to the processing of personal data and on the free movement of such data;
‘the data exporter’ means the controller who transfers the personal data;
‘the data importer’ means the processor who agrees to receive from the data exporter personal data intended for processing on his behalf after the transfer in accordance with his instructions and the terms of the Clauses and who is not subject to a third country’s system ensuring adequate protection within the meaning of Article 25(1) of Directive 95/46/EC;
‘the subprocessor’ means any processor engaged by the data importer or by any other subprocessor of the data importer who agrees to receive from the data importer or from any other subprocessor of the data importer personal data exclusively intended for processing activities to be carried out on behalf of the data exporter after the transfer in accordance with his instructions, the terms of the Clauses and the terms of the written subcontract;
‘the applicable data protection law’ means the legislation protecting the fundamental rights and freedoms of individuals and, in particular, their right to privacy with respect to the processing of personal data applicable to a data controller in the Member State in which the data exporter is established;
‘technical and organisational security measures’ means those measures aimed at protecting personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorised disclosure or access, in particular where the processing involves the transmission of data over a network, and against all other unlawful forms of processing.

Clause 2: Details of the transfer

The details are specified in Appendix 1 which forms an integral part of the Clauses.

Clause 3: Third-party beneficiary clause

The data subject can enforce against the data exporter this Clause, Clause 4(b) to (i), Clause 5(a) to (e), and (g) to (j), Clause 6(1) and (2), Clause 7, Clause 8(2), and Clauses 9 to 12 as third-party beneficiary.

The data subject can enforce against the data importer this Clause, Clause 5(a) to (e) and (g), Clause 6, Clause 7, Clause 8(2), and Clauses 9 to 12, in cases where the data exporter has factually disappeared or has ceased to exist in law unless any successor entity has assumed the entire legal obligations of the data exporter by contract or by operation of law, as a result of which it takes on the rights and obligations of the data exporter, in which case the data subject can enforce them against such entity.

The data subject can enforce against the subprocessor this Clause, Clause 5(a) to (e) and (g), Clause 6, Clause 7, Clause 8(2), and Clauses 9 to 12, in cases where both the data exporter and the data importer have factually disappeared or ceased to exist in law or have become insolvent, unless any successor entity has assumed the entire legal obligations of the data exporter by contract or by operation of law as a result of which it takes on the rights and obligations of the data exporter, in which case the data subject can enforce them against such entity. Such third-party liability of the subprocessor shall be limited to its own processing operations under the Clauses.

The parties do not object to a data subject being represented by an association or other body if the data subject so expressly wishes and if permitted by national law.

Clause 4: Obligations of the data exporter

The data exporter agrees and warrants:

that the processing, including the transfer itself, of the personal data has been and will continue to be carried out in accordance with the relevant provisions of the applicable data protection law (and, where applicable, has been notified to the relevant authorities of the Member State where the data exporter is established) and does not violate the relevant provisions of that State;
that it has instructed and throughout the duration of the personal data-processing services will instruct the data importer to process the personal data transferred only on the data exporter’s behalf and in accordance with the applicable data protection law and the Clauses;
that the data importer will provide sufficient guarantees in respect of the technical and organisational security measures specified in Appendix 2 to this contract;
that after assessment of the requirements of the applicable data protection law, the security measures are appropriate to protect personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorised disclosure or access, in particular where the processing involves the transmission of data over a network, and against all other unlawful forms of processing, and that these measures ensure a level of security appropriate to the risks presented by the processing and the nature of the data to be protected having regard to the state of the art and the cost of their implementation;
that it will ensure compliance with the security measures;
that, if the transfer involves special categories of data, the data subject has been informed or will be informed before, or as soon as possible after, the transfer that its data could be transmitted to a third country not providing adequate protection within the meaning of Directive 95/46/EC;
to forward any notification received from the data importer or any subprocessor pursuant to Clause 5(b) and Clause 8(3) to the data protection supervisory authority if the data exporter decides to continue the transfer or to lift the suspension;
to make available to the data subjects upon request a copy of the Clauses, with the exception of Appendix 2, and a summary description of the security measures, as well as a copy of any contract for subprocessing services which has to be made in accordance with the Clauses, unless the Clauses or the contract contain commercial information, in which case it may remove such commercial information;
that, in the event of subprocessing, the processing activity is carried out in accordance with Clause 11 by a subprocessor providing at least the same level of protection for the personal data and the rights of data subject as the data importer under the Clauses; and
that it will ensure compliance with Clause 4(a) to (i).

Clause 5: Obligations of the data importer

The data importer agrees and warrants:

to process the personal data only on behalf of the data exporter and in compliance with its instructions and the Clauses; if it cannot provide such compliance for whatever reasons, it agrees to inform promptly the data exporter of its inability to comply, in which case the data exporter is entitled to suspend the transfer of data and/or terminate the contract;
that it has no reason to believe that the legislation applicable to it prevents it from fulfilling the instructions received from the data exporter and its obligations under the contract and that in the event of a change in this legislation which is likely to have a substantial adverse effect on the warranties and obligations provided by the Clauses, it will promptly notify the change to the data exporter as soon as it is aware, in which case the data exporter is entitled to suspend the transfer of data and/or terminate the contract;
that it has implemented the technical and organisational security measures specified in Appendix 2 before processing the personal data transferred;
that it will promptly notify the data exporter about: any legally binding request for disclosure of the personal data by a law enforcement authority unless otherwise prohibited, such as a prohibition under criminal law to preserve the confidentiality of a law enforcement investigation, any accidental or unauthorised access; and any request received directly from the data subjects without responding to that request, unless it has been otherwise authorised to do so;
to deal promptly and properly with all inquiries from the data exporter relating to its processing of the personal data subject to the transfer and to abide by the advice of the supervisory authority with regard to the processing of the data transferred;
at the request of the data exporter to submit its data-processing facilities for audit of the processing activities covered by the Clauses which shall be carried out by the data exporter or an inspection body composed of independent members and in possession of the required professional qualifications bound by a duty of confidentiality, selected by the data exporter, where applicable, in agreement with the supervisory authority;
to make available to the data subject upon request a copy of the Clauses, or any existing contract for subprocessing, unless the Clauses or contract contain commercial information, in which case it may remove such commercial information, with the exception of Appendix 2 which shall be replaced by a summary description of the security measures in those cases where the data subject is unable to obtain a copy from the data exporter;
that, in the event of subprocessing, it has previously informed the data exporter and obtained its prior written consent;
that the processing services by the subprocessor will be carried out in accordance with Clause 11;
to send promptly a copy of any subprocessor agreement it concludes under the Clauses to the data exporter.

Clause 6: Liability

The parties agree that any data subject, who has suffered damage as a result of any breach of the obligations referred to in Clause 3 or in Clause 11 by any party or subprocessor is entitled to receive compensation from the data exporter for the damage suffered.

If a data subject is not able to bring a claim for compensation in accordance with paragraph 1 against the data exporter, arising out of a breach by the data importer or his subprocessor of any of their obligations referred to in Clause 3 or in Clause 11, because the data exporter has factually disappeared or ceased to exist in law or has become insolvent, the data importer agrees that the data subject may issue a claim against the data importer as if it were the data exporter, unless any successor entity has assumed the entire legal obligations of the data exporter by contract of by operation of law, in which case the data subject can enforce its rights against such entity.

The data importer may not rely on a breach by a subprocessor of its obligations in order to avoid its own liabilities.

If a data subject is not able to bring a claim against the data exporter or the data importer referred to in paragraphs 1 and 2, arising out of a breach by the subprocessor of any of their obligations referred to in Clause 3 or in Clause 11 because both the data exporter and the data importer have factually disappeared or ceased to exist in law or have become insolvent, the subprocessor agrees that the data subject may issue a claim against the data subprocessor with regard to its own processing operations under the Clauses as if it were the data exporter or the data importer, unless any successor entity has assumed the entire legal obligations of the data exporter or data importer by contract or by operation of law, in which case the data subject can enforce its rights against such entity. The liability of the subprocessor shall be limited to its own processing operations under the Clauses.

Clause 7: Mediation and jurisdiction

The data importer agrees that if the data subject invokes against it third-party beneficiary rights and/or claims compensation for damages under the Clauses, the data importer will accept the decision of the data subject:
to refer the dispute to mediation, by an independent person or, where applicable, by the supervisory authority;
to refer the dispute to the courts in the Member State in which the data exporter is established.
The parties agree that the choice made by the data subject will not prejudice its substantive or procedural rights to seek remedies in accordance with other provisions of national or international law.

Clause 8: Cooperation with supervisory authorities

The data exporter agrees to deposit a copy of this contract with the supervisory authority if it so requests or if such deposit is required under the applicable data protection law.

The parties agree that the supervisory authority has the right to conduct an audit of the data importer, and of any subprocessor, which has the same scope and is subject to the same conditions as would apply to an audit of the data exporter under the applicable data protection law.

The data importer shall promptly inform the data exporter about the existence of legislation applicable to it or any subprocessor preventing the conduct of an audit of the data importer, or any subprocessor, pursuant to paragraph 2. In such a case the data exporter shall be entitled to take the measures foreseen in Clause 5(b).

Clause 9: Governing law

The Clauses shall be governed by the law of the country or state in which the data exporter is established.

Clause 10: Variation of the contract

The parties undertake not to vary or modify the Clauses. This does not preclude the parties from adding clauses on business related issues where required as long as they do not contradict the Clause.

Clause 11: Subprocessing

The data importer shall not subcontract any of its processing operations performed on behalf of the data exporter under the Clauses without the prior written consent of the data exporter. Where the data importer subcontracts its obligations under the Clauses, with the consent of the data exporter, it shall do so only by way of a written agreement with the subprocessor which imposes the same obligations on the subprocessor as are imposed on the data importer under the Clauses. Where the subprocessor fails to fulfil its data protection obligations under such written agreement the data importer shall remain fully liable to the data exporter for the performance of the subprocessor’s obligations under such agreement.

The prior written contract between the data importer and the subprocessor shall also provide for a third-party beneficiary clause as laid down in Clause 3 for cases where the data subject is not able to bring the claim for compensation referred to in paragraph 1 of Clause 6 against the data exporter or the data importer because they have factually disappeared or have ceased to exist in law or have become insolvent and no successor entity has assumed the entire legal obligations of the data exporter or data importer by contract or by operation of law. Such third-party liability of the subprocessor shall be limited to its own processing operations under the Clauses.

The provisions relating to data protection aspects for subprocessing of the contract referred to in paragraph 1 shall be governed by the law of the Member State in which the data exporter is established.

The data exporter shall keep a list of subprocessing agreements concluded under the Clauses and notified by the data importer pursuant to Clause 5(j), which shall be

updated at least once a year. The list shall be available to the data exporter’s data protection supervisory authority.

Clause 12: Obligation after the termination of personal data-processing services

The parties agree that on the termination of the provision of data-processing services, the data importer and the subprocessor shall, at the choice of the data exporter, return all the personal data transferred and the copies thereof to the data exporter or shall destroy all the personal data and certify to the data exporter that it has done so, unless legislation imposed upon the data importer prevents it from returning or destroying all or part of the personal data transferred. In that case, the data importer warrants that it will guarantee the confidentiality of the personal data transferred and will not actively process the personal data transferred anymore.

The data importer and the subprocessor warrant that upon request of the data exporter and/or of the supervisory authority, it will submit its data-processing facilities for an audit of the measures referred to in paragraph 1.

Sub-Processor	Description	Privacy Policy
Stripe	Credit card payment processing	https://stripe.com/privacy
Meta (Facebook)	Pixel tracking for visits and sales	https://www.facebook.com/policy.php
Google Analytics	Website traffic and user behavior analysis (anonymized)	https://policies.google.com/privacy
Google Optimize	Content variant testing (anonymized)	https://policies.google.com/privacy

APPENDIX 2: Technical and Organizational Security Measures

This Appendix forms part of the Clauses.

Description of the technical and organisational security measures implemented by the data importer in accordance with Clauses 4(d) and 5(c) (or document/legislation attached):

Tamio GmbH currently observes the security practices described in this Appendix 2. Notwithstanding any provision to the contrary otherwise agreed to by data exporter, Tamio GmbH may modify or update these practices at its discretion provided that such modification and update does not result in a material degradation in the protection offered by these practices. All capitalised terms not otherwise defined herein shall have the meanings as set forth in the Agreement.

1. Access Control

Preventing Unauthorised Product Access

Outsourced processing: Tamio GmbH hosts its Service with outsourced cloud infrastructure providers. Additionally, Tamio GmbH maintains contractual relationships with vendors in order to provide the Service in accordance with our Data Processing Agreement. Tamio GmbH relies on contractual agreements, privacy policies, and vendor compliance programs in order to protect data processed or stored by these vendors.

Physical and environmental security: Tamio GmbH hosts its product infrastructure with multi- tenant, outsourced infrastructure providers. The physical and environmental security controls are audited for ISO 27001 compliance, among other certifications.

Authentication: Tamio GmbH implemented a uniform password policy for its customer products. Customers who interact with the products via the user interface must authenticate before accessing non-public customer data.

Authorization: Customer data is stored in multi-tenant storage systems accessible to Customers via only application user interfaces and application programming interfaces. Customers are not allowed direct access to the underlying application infrastructure. The authorization model in each of Tamio GmbH’s products is designed to ensure that only the appropriately assigned individuals can access relevant features, views, and customization options. Authorization to data sets is performed through validating the user’s permissions against the attributes associated with each data set.

Application Programming Interface (API) access: Public product APIs may be accessed using an API key or through Oauth authorization.

2. Preventing Unauthorised Product Use

Tamio GmbH implements industry standard access controls and detection capabilities for the internal networks that support its products.

Access controls: Network access control mechanisms are designed to prevent network traffic using unauthorised protocols from reaching the product infrastructure. The technical measures implemented differ between infrastructure providers and include Virtual Private Cloud (VPC) implementations, security group assignment, and traditional firewall rules.

Intrusion detection and prevention: Tamio GmbH implemented a Web Application Firewall (WAF) solution to protect hosted customer websites and other internet-accessible applications. The WAF is designed to identify and prevent attacks against publicly available network services.

Static code analysis: Security reviews of code stored in Tamio GmbH’s source code repositories is performed, checking for coding best practices and identifiable software flaws.

Penetration testing: Tamio GmbH maintains relationships with industry recognized penetration testing service providers for four annual penetration tests. The intent of the penetration tests is to identify and resolve foreseeable attack vectors and potential abuse scenarios.

Bug bounty: A bug bounty program invites and incentivizes independent security researchers to ethically discover and disclose security flaws. Tamio GmbH implemented a bug bounty program in an effort to widen the available opportunities to engage with the security community and improve the product defences against sophisticated attacks.

3. Limitations of Privilege & Authorization Requirements

Product access: A subset of Tamio GmbH’s employees have access to the products and to customer data via controlled interfaces. The intent of providing access to a subset of employees is to provide effective customer support, to troubleshoot potential problems, to detect and respond to security incidents and implement data security. Access is enabled through “just in time” requests for access; all such requests are logged. Employees are granted access by role, and reviews of high risk privilege grants are initiated daily. Employee roles are reviewed at least once every six months.

Background checks: All Tamio GmbH employees undergo a third-party background check prior to being extended an employment offer, in accordance with the applicable laws. All employees are required to conduct themselves in a manner consistent with company guidelines, non- disclosure requirements, and ethical standards.

4. Transmission Control

In-transit: Tamio GmbH makes HTTPS encryption (also referred to as SSL or TLS) available on every one of its login interfaces and for free on every customer site hosted on the Tamio GmbH products. Tamio GmbH’s HTTPS implementation uses industry standard algorithms and certificates.

At-rest: Tamio GmbH stores user passwords following policies that follow industry standard practices for security. With effect 25 May 2018, Tamio GmbH has implemented technologies to ensure that stored data is encrypted at rest.

5. Input Control

Detection: Tamio GmbH designed its infrastructure to log extensive information about the system behaviour, traffic received, system authentication, and other application requests. Internal systems aggregated log data and alert appropriate employees of malicious, unintended, or anomalous activities. Tamio GmbH personnel, including security, operations, and support personnel, are responsive to known incidents.

Response and tracking: Tamio GmbH maintains a record of known security incidents that includes description, dates and times of relevant activities, and incident disposition. Suspected and confirmed security incidents are investigated by security, operations, or support personnel; and appropriate resolution steps are identified and documented. For any confirmed incidents, Tamio GmbH will take appropriate steps to minimise product and Customer damage or unauthorised disclosure.

Communication: If Tamio GmbH becomes aware of unlawful access to Customer data stored within its products, Tamio GmbH will: 1) notify the affected Customers of the incident; 2) provide a description of the steps Tamio GmbH is taking to resolve the incident; and 3) provide status updates to the Customer contact, as Tamio GmbH deems necessary. Notification(s) of incidents, if any, will be delivered to one or more of the Customer’s contacts in a form Tamio GmbH selects, which may include via email or telephone.

6. Availability Control

Infrastructure availability: The infrastructure providers use commercially reasonable efforts to ensure a minimum of 99.95% uptime. The providers maintain a minimum of N+1 redundancy to power, network, and HVAC services.

Fault tolerance: Backup and replication strategies are designed to ensure redundancy and fail-over protections during a significant processing failure. Customer data is backed up to multiple durable data stores and replicated across multiple availability zones.

Online replicas and backups: Where feasible, production databases are designed to replicate data between no less than 1 primary and 1 secondary database. All databases are backed up and maintained using at least industry standard methods.

Tamio GmbH’s products are designed to ensure redundancy and seamless failover. The server instances that support the products are also architected with a goal to prevent single points of failure. This design assists Tamio GmbH operations in maintaining and updating the product applications and backend while limiting downtime.

Contact Information:
Tamio GmbH
Rahmannstr. 11
65760 Eschborn, Germany
VAT: DE329477216
Managing Director: George Spitaliotis

This DPA is effective August 20, 2025, and applies to all customer registrations on or after this date with Tamio GmbH.