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Data Processing Agreement

Last Updated: 6th March 2026

This Recruiterflow Data Processing Agreement ("DPA"), that includes the Standard Contractual Clauses adopted by the European Commission, and where applicable the UK International Data Transfer Addendum, reflects the parties' agreement with respect to the terms governing the Processing of Personal Data under Recruiterflow's Terms of Service. This DPA is an amendment to the Agreement and is effective upon its incorporation into the Agreement, which incorporation may be specified in the Agreement, an Order or an executed amendment to the Agreement. Upon its incorporation into the Agreement, the DPA will form a part of the Agreement. The term of this DPA shall follow the term of the Agreement. Terms not otherwise defined herein shall have the meaning as set forth in the Agreement.

The term of this DPA shall follow the term of the Agreement. Terms not otherwise defined herein shall have the meaning as set forth in the Agreement.

THIS DPA INCLUDES:

  1. Standard Contractual Clauses (EU) 2021/914, attached hereto as EXHIBIT 1.
    • Annex I to the Standard Contractual Clauses, which includes details of the parties, the processing, and the competent supervisory authority
    • Annex II to the Standard Contractual Clauses, which includes a description of the technical and organisational security measures implemented by the data importer.
    • Annex III to the Standard Contractual Clauses, which includes the list of sub-processors.
  2. UK International Data Transfer Addendum to the EU Standard Contractual Clauses, attached hereto as EXHIBIT 2.
  3. List of Sub-Processors, attached hereto as EXHIBIT 3.
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1. 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 (a) the GDPR; (b) the UK GDPR and the UK Data Protection Act 2018;and (c) all local laws and regulations in any Member State of the European Union or the United Kingdom which implement, supplement, amend or replace any of the foregoing, as amended, repealed, consolidated or replaced from time to time. The terms "process", "processes" and "processed" will be construed accordingly.

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

"GDPR" means the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard tothe processing of personal data and on the free movement of such data.

"UK GDPR" means the GDPR as it forms part of the law of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018, as amended by the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit)Regulations 2019.

"Instruction" means the written, documented instruction, issued by Controller to Processor, and directing the same to perform a specific action with regard to Personal Data (including, but not limited to, depersonalising, blocking, deletion, making available).

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

"Personal Data Breach" means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Personal Data transmitted, stored or otherwise processed.

"Processing" means any operation or set of operations which is performed on Personal Data, encompassing the collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction or erasure of Personal Data. "Processor" means a natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller.

"Standard Contractual Clauses" or "SCCs" means the standard contractual clauses for the transfer of personal data to third countries pursuant to Commission Implementing Decision (EU)2021/914 of 4 June 2021, as set out in Exhibit 1.

"UK Addendum" means the International Data Transfer Addendum to the EU Commission Standard Contractual Clauses issued by the UK Information Commissioner under section 119A(1)of the Data Protection Act 2018, as set out in Exhibit 2.
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2. DETAILS OF THE PROCESSING

2(a) Categories of Data Subjects
Controller's Contacts and other end users including Controller's employees, contractors, collaborators, customers, prospects, suppliers and subcontractors. Data Subjects also include individuals attempting to communicate with or transfer Personal Data to the Controller's end users. In the context of recruitment services, Data Subjects include candidates and applicants.

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2(b) Types of Personal Data
Contact Information, the extent of which is determined and controlled by the User in its sole discretion, and other Personal Data such as navigational data (including website usageinformation), email data, system usage data, application integration data, and other electronic data submitted, stored, sent, or received by end users via the Subscription Service. In the context of recruitment, this may include CVs/résumés, employment history, education records, and other candidate profile data.

2(c) Special Categories of Data
The parties acknowledge that, in the context of recruitment processing, Controller may upload or process special categories of personal data (as defined in Article 9 of the GDPR and section 10 of the UK Data Protection Act 2018), which may include data revealing racial or ethnic origin, health data, trade union membership, or other sensitive information contained within candidate records. Where Controller uploads such data, the provisions of Section 4(i) of this DPA shall apply.

2(d) Subject-Matter and Nature of the Processing
The subject-matter of Processing of Personal Data by Processor is the provision of the services to the Controller that involves the Processing of Personal Data. Personal Data will be subject to those Processing activities as may be specified in the Agreement and an Order.
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2(e) Purpose of the Processing Personal Data will be Processed for purposes of providing the services set out and otherwise agreed to in the Agreement and any applicable Order.2(f) Duration of the Processing Personal Data will be Processed for the duration of the Agreement, subject to Section 4 of this DPA.

2(f) Duration of the Processing Personal Data will be Processed for the duration of the Agreement,subject to Section 4 of this DPA.
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3. USER RESPONSIBILITY

Within the scope of the Agreement and in its use of the services, Controller shall be solely responsible for complying with the statutory requirements relating to data protection and privacy, in particular regarding the disclosure and transfer of Personal Data to the Processor and the Processing of Personal Data. For the avoidance of doubt, Controller's instructions for the Processing of Personal Data shall comply with the Data Protection Law. This DPA is User's complete and final instruction to Recruiterflow in relation to Personal Data and additional instructions outside the scope of DPA would require prior written agreement between the parties. Instructions shall initially be specified in the Agreement and may, from time to time thereafter, be amended, amplified or replaced by Controller in separate written instructions (as individual instructions).

Controller shall inform Processor without undue delay and comprehensively about any errors or irregularities related to statutory provisions on the Processing of Personal Data.

Where Controller uploads or processes special categories of personal data, Controller shall be solely responsible for ensuring that a valid legal basis exists for such processing (including, where required, obtaining explicit consent from the relevant Data Subjects) and for conducting any required data protection impact assessment.

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4. OBLIGATIONS OF PROCESSOR

4(a) Compliance with Instructions
The parties acknowledge and agree that User is the Controller of Personal Data and Recruiterflow is the Processor of that data. Processor shall collect, process and use Personal Data only within the scope of Controller's Instructions. If the Processor believes that an Instructionof the Controller infringes the Data Protection Law, it shall immediately inform the Controller without delay. If Processor cannot process Personal Data in accordance with the Instructions due to a legal requirement under any applicable European Union, United Kingdom or Member State law, Processor will (i) promptly notify the Controller of that legal requirement before the relevant Processing to the extent permitted by the Data Protection Law; and (ii) cease all Processing(other than merely storing and maintaining the security of the affected Personal Data) until such time as the Controller issues new instructions with which Processor is able to comply. If this provision is invoked, Processor will not be liable to the Controller under the Agreement for any failure to perform the applicable services until such time as the Controller issues new instructions in regard to the Processing.

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4(b) Security

‍Processor shall take the appropriate technical and organisational measures to adequately protect Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to Personal Data, described under Annex II to the Standard Contractual Clauses. Such measures include, but are not limited to:

  1. (i) the prevention of unauthorised persons from gaining access to Personal Data Processing systems (physical access control);
  2. the prevention of Personal Data Processing systems from being used without authorisation (logical access control);
  3. ensuring that persons entitled to use a Personal Data Processing system gain access only to such Personal Data as they are entitled to accessing in accordance with their access rights, and that, in the course of Processing or use and after storage, Personal Data cannot be read, copied, modified or deleted without authorisation (data access control);
  4. ensuring that Personal Data cannot be read, copied, modified or deleted without authorisation during electronic transmission, transport or storage on storage media, and that the target entities for any transfer of Personal Data by means of data transmission facilities can be established and verified (data transfer control);
  5. ensuring the establishment of an audit trail to document whether and by whom Personal Data have been entered into, modified in, or removed from Personal Data Processing systems(entry control);
  6. ensuring that Personal Data is Processed solely in accordance with the Instructions (control of instructions);
  7. ensuring that Personal Data is protected against accidental destruction or loss(availability control).

Upon Controller's request, Processor shall provide a current Personal Data protection and security program relating to the Processing here under. Processor will facilitate Controller's compliance with the Controller's obligation to implement security measures with respect to Personal Data (including if applicable Controller's obligations pursuant to Articles 32 to 34(inclusive) of the GDPR and the equivalent provisions of the UK GDPR), by (i) implementing and maintaining the security measures described under Annex II, (ii) complying with the terms of Section 4(d) (Personal Data Breaches); and (iii) providing the Controller with information inrelation to the Processing in accordance with Section 5 (Audits).

4(c) Confidentiality
Processor shall ensure that any personnel whom Processor authorises to process Personal Data on its behalf is subject to confidentiality obligations with respect to that Personal Data. The undertaking to confidentiality shall continue after the termination of the above-entitled activities.

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