Effective Date: August 1, 2026 This Data Processing Addendum (“DPA”) sets out the terms that apply when Personal Data is Processed by Crewfare, Inc, a Delaware corporation (“Crewfare” or “Company”). The primary place of business for Crewfare is 2678 Edgewater Court, Weston, Florida 33332, USA. This DPA applies under the applicable terms of service or other agreement between Crewfare and its customer (the “Agreement”). The purpose of the DPA is to ensure that Processing is conducted in accordance with applicable data protection laws and respects the rights of individuals whose Personal Data is Processed under the Agreement. Any terms not defined in this DPA shall have the meaning assigned to them in the Agreement. This DPA applies where Company is the Processor and Customer is the Controller.

Processing Personal Data

1. Relationship of the Parties. Customer is the “Controller” and Company is the “Processor,” as such terms are defined under the General Data Protection Regulation ((EU) 2016/679) (“GDPR”) with respect to the Personal Data Processed under the Agreement. In some circumstances, Customer may be a Processor, in which case Customer appoints Company as Customer’s Subprocessor, which shall not change the obligations of either party under this DPA.
2. Customer’s Processing of Personal Data. “Personal Data” and “Processing” will have the same meaning as set forth in the GDPR. Customer shall, in the use of the Services (as defined in the Agreement), Process Personal Data in accordance with the requirements of all applicable data protection laws. To the extent Customer acquires Personal Data, Customer shall have sole responsibility for the legality of Personal Data and the means by which Customer acquired Personal Data.
3. Company’s Processing of Personal Data. As Customer’s Processor, Company shall Process Personal Data for the following purposes:
   1. Processing in accordance with the Agreement;
   2. Processing initiated by Authorized Users in their use of the Services according to the Agreement;
   3. Processing to comply with other reasonable instructions provided by Customer; and
   4. In compliance with all applicable data protection laws.
4. Company will promptly notify the Customer in writing if, in its opinion, the Customer’s instructions do not comply with all applicable data protection laws.
5. Company will ensure that all of its employees:
   1. are informed of the confidential nature of the Personal Data and are bound by confidentiality obligations and use restrictions in respect of the Personal Data;
   2. have undertaken training on applicable data protection laws relating to handling Personal Data and how it applies to their particular duties; and
   3. are aware of both the Company’s duties and their personal duties and obligations under applicable data protection laws and this DPA.

Subprocessing

1. Customer acknowledges and agrees that Company may retain certain Subprocessors to Process Personal Data on Company’s behalf in order to provide Services under the Agreement. Company’s Subprocessors are identified in Company’s GDPR Statement at https://crewfare.com/gdpr, which is maintained as the canonical and dated list.
2. Prior to a Subprocessor’s Processing of Personal Data, Company will require contractual obligations of the Subprocessor that are substantially the same as those imposed on Company under this DPA, in particular in relation to requiring appropriate technical and organizational data security measures.
3. Company remains liable for its Subprocessors’ performance under this DPA to the same extent Company is liable for its own performance.
4. Other than those Subprocessors listed at the URL above, Company may only authorize any additional Subprocessors to Process Personal Data on its behalf after notifying Customer in advance in writing of its intention to utilize such Subprocessor.
5. Customer may object to Company’s use of a new Subprocessor by notifying Company promptly in writing within 14 days of receipt of written notice. After receiving an objection to the use of a new Subprocessor, the Company will work with Customer to determine the appropriate course of action. Should Company not be able to provide a viable solution to alleviate Customer’s concerns within 14 days, Customer may terminate the Agreement without further liability and will be refunded any pre-paid unused fees.

Security

1. 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, Company shall in relation to Personal Data implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including, as appropriate, the measures referred to in Article 32(1) of the GDPR, including as appropriate:
   1. the pseudonymisation and encryption of Personal Data;
   2. the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
   3. the ability to restore the availability and access to Personal Data in a timely manner in the event of a physical or technical incident; and
   4. a process for regularly testing, assessing and evaluating the effectiveness of the security measures.
2. In assessing the appropriate level of security, Company shall consider the risks that are presented by Processing, in particular from a Personal Data Breach. “Personal Data Breach” will have the same meaning as set forth in the GDPR.
3. Company shall notify Customer without undue delay, but in no event longer than 72 hours, upon becoming aware of:
   1. the loss, unintended destruction or damage, corruption, or unusability of part or all of the Personal Data. Company will restore such Personal Data at its own expense as soon as possible;
   2. any accidental, unauthorized or unlawful processing of the Personal Data; or
   3. a Personal Data Breach or suspected Personal Data Breach affecting Customer Personal Data.
4. Where Company becomes aware of Clause 3(a), 3(b) and/or 3(c) above, it shall, without undue delay, also provide the Customer with the following information:
   1. description of the nature of the incident, including the categories of in-scope Personal Data and approximate number of both Data Subjects and the Personal Data records concerned;
   2. the likely consequences; and
   3. a description of the measures taken or proposed to be taken to address the incident, including measures to mitigate its possible adverse effects.
5. Immediately following any accidental, unauthorized or unlawful Personal Data processing or Personal Data Breach, Company will investigate the matter. Further, Company will reasonably cooperate with the Customer including but not limited to:
   1. assisting with any investigation;
   2. making available all relevant records, logs, files, data reporting and other materials required to comply with all data protection legislation or as otherwise reasonably requested by the Customer; and
   3. taking reasonable and prompt steps to mitigate the effects and to minimize any damage resulting from the Personal Data Breach or accidental, unauthorized or unlawful Personal Data processing.
6. Company will not inform any third party of any accidental, unauthorized or unlawful processing of all or part of the Personal Data and/or a Personal Data Breach without first obtaining the Customer’s prior written consent, except when required to do so by law.
7. Company agrees that the Customer has the sole right to determine whether to provide notice of the accidental, unauthorized or unlawful processing and/or the Personal Data Breach to any Data Subjects, the relevant Supervisory Authority, other in-scope regulators, law enforcement agencies or others, as required by law or regulation or in the Customer’s discretion, including the contents and delivery method of the notice.

Payment Card Data

1. Where the Services include the transmission of payment card information to an accommodation provider, such information is stored in tokenized form with a PCI DSS-validated third-party vault provider identified in Company’s Subprocessor list.
2. Company systems do not transmit, process, or store primary account numbers. Card data is rendered directly from the vault provider into vault-hosted elements within the authorized recipient’s browser. Card verification values and cardholder names are not made available through the Services.
3. Disclosure of payment card information occurs only through a controlled reveal function which requires per-use re-authentication via a single-use code, is scoped to the recipient’s own properties, is rate-limited, expires seven (7) days following the applicable event, and is logged. Company logs each access, including the identity of the accessing user, the applicable reservation, and the time of access, and may make such logs available to Customer.
4. Payment card information is purged from the vault thirty (30) days following the later of guest checkout or the applicable event end date, or upon termination of the Agreement, whichever is earlier.
5. Each party shall maintain compliance with the Payment Card Industry Data Security Standard as applicable to its respective role.

Rights of Data Subjects

1. “Data Subject” will have the same meaning as set forth in the GDPR. Taking into account the nature of the Processing, Company shall assist Customer by implementing appropriate technical and organizational measures, insofar as possible, for the fulfillment of Customer’s obligations, to enable Customer to respond to requests to exercise Data Subject rights under applicable data protection laws, including subject access rights, the rights to rectify, port and erase personal data, object to the processing and automated processing of personal data, and restrict the processing of personal data, and to comply with information or assessment notices served on the Customer by the relevant Supervisory Authority under data protection legislation.
2. Company shall:
   1. Promptly notify Customer if it receives a request from a Data Subject under any applicable data protection laws in respect of Customer Personal Data and/or any complaint, notice or communication that relates directly or indirectly to the processing of the Personal Data or to either party’s compliance with data protection legislation; and
   2. Ensure that it does not respond to any request from a Data Subject except on documented instructions of Customer or as required by applicable data protection laws to which Company is subject, in which case Company shall, to the extent permitted by applicable data protection laws, inform Customer of that legal requirement before responding to the request.

Retention and Deletion of Customer Personal Data

1. Company retains the minimum amount of Personal Data in order to provide its Services.
2. Personal Data collected through a Customer’s use of Company’s travel booking, travel management, and SaaS services is retained for the duration of the Agreement and processed solely to provide those services.
3. Where Personal Data is retained after it is no longer needed to provide the Services, it is de-identified or encrypted and stored solely to maintain records required for legal, tax, accounting, or dispute-resolution purposes.
4. Personal Data processed by Company with respect to all its products and services is retained for the duration of the Agreement with Customer and is then automatically deleted thirty (30) calendar days after the termination of the Agreement.
5. Payment card information is purged in accordance with the Payment Card Data section above.
6. Upon termination of the Services for which Company is Processing Personal Data, Company shall, upon Customer’s written request and subject to the limitations in the Agreement and unless prevented by applicable data protection laws, securely destroy any Customer Personal Data that has not already been deleted.
7. If any law, regulation, or government or regulatory body requires Company to retain any documents or materials or Personal Data that Company would otherwise be required to return or destroy, it will notify the Customer in writing of that retention requirement, giving details of the documents, materials or Personal Data that it must retain, the legal basis for retention, and establishing a specific timeline for deletion or destruction once the retention requirement ends.

Data Protection Impact Assessment

1. Upon Customer’s reasonable request, Company shall provide Customer with commercially reasonable cooperation and assistance needed to fulfill Customer’s obligation under the GDPR to carry out a data protection impact assessment related to Customer’s use of the Services, to the extent Customer does not otherwise have access to the relevant information, and to the extent such information is available to Company.
2. Company shall provide commercially reasonable assistance to Customer in the cooperation or prior consultation with the Supervisory Authority to the extent required under the GDPR or other applicable data protection laws. “Supervisory Authority” will have the same meaning as set forth in the GDPR.

Audit Rights

1. Company will permit the Customer or a representative to audit Company’s compliance with this DPA, on at least seven days’ notice. Company will give the Customer all necessary assistance to conduct such audits. Where such an audit occurs, Customer shall bear all of its own costs of conducting the audit or those of its representative. The assistance may include, but is not limited to:
   1. remote electronic access to, and copies of, the records and any other information held on systems storing the Personal Data;
   2. access to and meetings with any of Company’s personnel reasonably necessary to provide all explanations and perform the audit effectively; and
   3. inspection of all records and the infrastructure, electronic data or systems, facilities, equipment or application software used to store or process the Personal Data.
2. The notice requirements in Section 1 above will not apply if (i) the Customer reasonably believes that a Personal Data Breach occurred, (ii) Company is in breach of any of its obligations under this DPA or any applicable data protection laws, or (iii) such audit is mandated by the relevant Supervisory Authority.
3. If a Personal Data Breach occurs or is occurring, or Company becomes aware of a breach of any of its obligations under this DPA or any applicable data protection laws, Company will:
   1. notify Customer promptly as detailed above;
   2. promptly conduct its own audit to determine the cause; and
   3. remedy any deficiencies identified by the audit within thirty days.

Records

1. Company will keep detailed, accurate and up-to-date written records regarding any processing of the Personal Data, including but not limited to the access, control and security of the Personal Data, approved Subprocessors, the processing purposes, categories of processing, any transfers of personal data to a third country and related safeguards, and a general description of the technical and organizational security measures (“Records”).
2. Company will ensure that the Records are sufficient to enable the Customer to verify Company’s compliance with its obligations under this DPA and Company will provide the Customer with copies of the Records upon request.
3. Company must review the information listed in the Annexes to this DPA at least once a year to confirm its current accuracy and suggest updates to it when required to reflect current practices.

Data Transfers

1. Company (and any Subprocessor) will only transfer or otherwise process the Personal Data outside the European Economic Area (“EEA”) or the United Kingdom subject to the Standard Contractual Clauses attached to this DPA.
2. Company may only process, or permit the processing of, the Personal Data outside the EEA under the following conditions:
   1. Company is processing the Personal Data in a territory which is subject to adequacy regulations under applicable data protection laws whereby the territory provides adequate protection for the privacy rights of individuals. Company must identify in Annex 1 the territory that is subject to such adequacy regulations; or
   2. Company participates in a valid cross-border transfer mechanism under applicable data protection laws, so that Company (and, where appropriate, the Customer) can ensure that appropriate safeguards are in place to ensure an adequate level of protection with respect to the privacy rights of individuals as required by Article 46 of the GDPR. Company must identify in Annex 1 the transfer mechanism that enables the parties to comply with these cross-border data transfer provisions and Company must immediately inform the Customer of any change to that status; or
   3. the transfer otherwise complies with applicable data protection laws for the reasons set out in Annex 1.
3. If any Personal Data transfer between the Customer and Company requires execution of Standard Contractual Clauses (“SCC”) in order to comply with applicable data protection laws (where the Customer is the entity exporting Personal Data to Company outside the EEA or the United Kingdom), the parties will complete all relevant details in, and execute, the SCC contained in Annex 2, and take all other actions required to legitimize the transfer including, but not limited to, entering into any required transfer agreement required by the United Kingdom’s ICO.
4. If the Customer consents to appointment by Company of a Subprocessor located outside the EEA or the United Kingdom in compliance with the provisions of the Subprocessing section, then the Customer authorizes Company to enter into the SCC contained in Annex 2 with the Subprocessor in Company’s name and on its behalf. Company will make the executed Subprocessor agreement with SCC available to the Customer upon request.
5. Transfers to accommodation providers. Where Company discloses Personal Data to an accommodation provider located outside the EEA or the United Kingdom in order to fulfill a reservation, that transfer is made on the basis that it is necessary for the performance of the contract between the data subject and the Customer, or of a contract concluded in the interest of the data subject between the Customer and Company, within the meaning of Article 49(1)(b) and (c) of the GDPR.

California Service Provider Provisions

1. For purposes of this section, “Business Purpose” shall mean the purposes or services described in the Agreement or as otherwise directed by the Customer; the terms “Collect,” “Consumer,” “Sell” and “Share” shall have the meanings given to them in Section 1798.140 of the California Consumer Privacy Act (as amended, the “CCPA”) and the California Privacy Rights Act (as amended, the “CPRA”). “Personal Data” shall mean “Personal Information” as defined in the CCPA and CPRA. The Company may be a “Service Provider” and the Customer may be a “Business” as both terms are defined in the CCPA and CPRA.
2. Company may not Sell or Share the Personal Data that it Collects or processes for the Customer.
3. Company shall only Collect and process Personal Data upon lawful documented instructions from the Customer, including those in the Agreement, this DPA and other documentation provided by the Customer. Company is prohibited from retaining, using or disclosing the Personal Data for any purpose other than for the Business Purpose, including retaining, using or disclosing the Personal Data for a commercial purpose other than the Business Purpose.
4. Company is prohibited from retaining, using or disclosing the Personal Data outside of the direct business relationship between the parties.
5. Company is prohibited from combining the Personal Data received from or on behalf of the Customer with Personal Data received or collected in other contexts (unless such combining is permitted under CPRA and its regulations and is reasonably necessary to perform the Business Purpose).

Annex 1 - Description of Processing

This Annex 1 forms part of the DPA and describes the processing that the Company will perform on behalf of the Customer.

Nature and Purpose of Processing

The processing relates to the following activities:

• Arranging, managing, and fulfilling accommodation reservations and event travel on behalf of the Customer.
• Transmission of rooming lists and reservation records to accommodation providers through the Digital Rooming List, including the receipt and recording of confirmation numbers, changes, and cancellations submitted by accommodation providers.
• Tokenized storage and controlled disclosure of payment method information to accommodation providers where a reservation is payable at the property.
• Providing software-as-a-service platforms for travel sourcing, travel management, and attendee booking.
• Personalization of travel experiences and software functionality based on user preferences.
• Customer support and communication regarding travel arrangements, software inquiries, and service feedback.
• Analysis of travel and software usage data, in de-identified or aggregated form, to improve service offerings, software features, and customer experience.
• Platform security, abuse prevention, and legal and regulatory compliance.

Categories of Data Subjects

The personal data to be processed concerns the following categories of data subjects:

• Individuals named in reservations, rooming lists, and booking records submitted to the Crewfare platforms, including guests, roommates, event staff, artists, production crew, vendors, and their designated travel contacts.
• Customers using Crewfare’s platforms for travel booking and management.
• Authorized users who register for and use Crewfare’s SaaS services.
• Individuals who interact with Crewfare’s customer service for travel or software-related queries.
• Participants in promotional or marketing activities of Crewfare.
• Users who visit Crewfare’s website or interact with its online platforms and software applications.

Categories of Personal Data

The personal data to be processed concerns the following categories of data:

• Personal identification details: first and last name, email address, postal address, and telephone numbers.
• Employer or organizational affiliation.
• Reservation and stay details: arrival and departure dates, room type, room assignment, roommate assignment, number of nights, rate, and confirmation numbers.
• Rooming list data: guest and roommate names, room assignments, and reservation status.
• Special requests and preferences submitted in connection with a reservation.
• Payment method information in tokenized form, and financial and billing information relating to payments, billing, and transaction history.
• SaaS user data: account details, access credentials, usage patterns, and preferences.
• Communication records: records of communications with Crewfare’s customer service.
• Digital footprint: IP addresses, device identifiers, website and software interaction data, and usage statistics.
• Marketing preferences.

Sensitive Data

Special requests submitted in connection with a reservation may contain data concerning health, disability, accessibility requirements, or dietary requirements. Such data is processed solely for the purpose of transmitting the request to the applicable accommodation provider so that it may be accommodated. Applied restrictions and safeguards: strict purpose limitation; access restricted to personnel with a documented business need; encryption in transit and at rest; logging of access; no use for analytics, profiling, or marketing; no onward transfer other than to the accommodation provider fulfilling the request.

Frequency of the Transfer

Continuous.

Duration of the Processing

Personal Data will be processed for the duration of the Agreement and solely as reasonably necessary for the Company to deliver the Services. Personal Data is deleted thirty (30) calendar days after termination of the Agreement, except where retention is required by applicable law. Payment card information is purged thirty (30) days following the later of guest checkout or the applicable event end date, or upon termination of the Agreement, whichever is earlier.

Processing Operations

Personal Data will be subject to the following basic processing activities:

• Data storage. Customer-provided Personal Data will be stored in Crewfare’s secure Amazon Web Services (AWS) cloud-based infrastructure, using data storage solutions that adhere to industry-standard encryption and security protocols. Payment card data is stored separately in a PCI DSS-validated third-party vault.
• Data entry and usage in Company’s databases. Personal Data will be entered into Crewfare’s databases in order to perform the Services, as follows:
  • For travel services: to manage and facilitate accommodation reservations, transmit rooming lists and reservation records to accommodation providers, record confirmation numbers and changes, maintain customer profiles, process payments, and provide customer support.
  • For SaaS services: to manage user accounts, personalize software interfaces and functionality, and provide ongoing software support and updates.
  • For customer support and communication: to maintain communication records with customers and users regarding bookings, software inquiries, and feedback.
  • For analytics: to analyze travel and software usage in de-identified or aggregated form for service improvement and product development.

Cross Border Transfers of Personal Data

Company’s legal basis for processing Personal Data outside the EEA or the United Kingdom in order to comply with cross-border transfer restrictions is the use of the Standard Contractual Clauses between Customer as “data exporter” and Company as “data importer.” Company is not currently self-certified to the EU-US Data Privacy Framework. Transfers to accommodation providers located outside the EEA or the United Kingdom are made under Article 49(1)(b) and (c) of the GDPR as necessary for the performance of the data subject’s reservation contract or a contract concluded in the data subject’s interest.

For Transfers to Sub-processors

Sub-processors are engaged for cloud hosting, payment processing, payment card vaulting and tokenization, consent management, email delivery, customer support, project management, analytics, and security monitoring, for the duration of the Agreement. The current list is maintained at https://crewfare.com/gdpr.

Annex 2 - Standard Contractual Clauses

The Standard Contractual Clauses annexed to Commission Implementing Decision (EU) 2021/914 of 4 June 2021 are incorporated into and form part of this DPA, completed as follows:

• Module Two (Transfer controller to processor) applies. Provisions marked for Modules One, Three, and Four do not apply. Customer is the “data exporter” and Company is the “data importer.”
• Clause 7 (Docking clause): included.
• Clause 9(a): Option 2 (General written authorisation) applies. The time period for prior notice of changes to the list of sub-processors is 14 days, and the current list is maintained at https://crewfare.com/gdpr.
• Clause 11(a): the optional independent-dispute-resolution language is not included.
• Clause 13: the supervisory authority identified in Annex I.C acts as competent supervisory authority.
• Clause 17 (Governing law): Option 1. These Clauses are governed by the law of Ireland.
• Clause 18(b): disputes shall be resolved before the courts of Ireland.
• Annexes I and II to the Clauses are completed as set out following the Clauses below.

UK transfers. For transfers subject to the UK GDPR, the Clauses apply as amended by the International Data Transfer Addendum to the EU Commission Standard Contractual Clauses (version B1.0) issued by the UK Information Commissioner under s.119A of the Data Protection Act 2018, in force 21 March 2022, with: Table 1 completed with the parties’ details in Annex I.A; Table 2 referring to these Clauses as completed above; Table 3 referring to Annexes I and II below; and Table 4 permitting either party to end the Addendum as set out in Section 19 of that Addendum. The Information Commissioner is the competent supervisory authority for such transfers. Swiss transfers. For transfers subject to the Swiss Federal Act on Data Protection, the Clauses apply with the adaptations required by the FDPIC, including references to the GDPR being understood as references to the FADP and the FDPIC as the competent supervisory authority. The full text of the Clauses follows.

Standard Contractual Clauses

Section I

Clause 1 - Purpose and scope

1. The purpose of these standard contractual clauses is to ensure compliance with the requirements of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation) for the transfer of personal data to a third country.
2. The Parties:
   1. the natural or legal person(s), public authority/ies, agency/ies or other body/ies (hereinafter ‘entity/ies’) transferring the personal data, as listed in Annex I.A (hereinafter each ‘data exporter’), and
   2. the entity/ies in a third country receiving the personal data from the data exporter, directly or indirectly via another entity also Party to these Clauses, as listed in Annex I.A (hereinafter each ‘data importer’) have agreed to these standard contractual clauses (hereinafter: ‘Clauses’).
3. These Clauses apply with respect to the transfer of personal data as specified in Annex I.B.
4. The Appendix to these Clauses containing the Annexes referred to therein forms an integral part of these Clauses.

Clause 2 - Effect and invariability of the Clauses

1. These Clauses set out appropriate safeguards, including enforceable data subject rights and effective legal remedies, pursuant to Article 46(1) and Article 46(2)(c) of Regulation (EU) 2016/679 and, with respect to data transfers from controllers to processors and/or processors to processors, standard contractual clauses pursuant to Article 28(7) of Regulation (EU) 2016/679, provided they are not modified, except to select the appropriate Module(s) or to add or update information in the Appendix. This does not prevent the Parties from including the standard contractual clauses laid down in these Clauses in a wider contract and/or to add other clauses or additional safeguards, provided that they do not contradict, directly or indirectly, these Clauses or prejudice the fundamental rights or freedoms of data subjects.
2. These Clauses are without prejudice to obligations to which the data exporter is subject by virtue of Regulation (EU) 2016/679.

Clause 3 - Third-party beneficiaries

1. Data subjects may invoke and enforce these Clauses, as third-party beneficiaries, against the data exporter and/or data importer, with the following exceptions:
   1. Clause 1, Clause 2, Clause 3, Clause 6, Clause 7;
   2. Clause 8 – Module One: Clause 8.5 (e) and Clause 8.9(b); Module Two: Clause 8.1(b), 8.9(a), (c), (d) and (e); Module Three: Clause 8.1(a), (c) and (d) and Clause 8.9(a), (c), (d), (e), (f) and (g); Module Four: Clause 8.1 (b) and Clause 8.3(b);
   3. Clause 9 – Module Two: Clause 9(a), (c), (d) and (e); Module Three: Clause 9(a), (c), (d) and (e);
   4. Clause 12 – Module One: Clause 12(a) and (d); Modules Two and Three: Clause 12(a), (d) and (f);
   5. Clause 13;
   6. Clause 15.1(c), (d) and (e);
   7. Clause 16(e);
   8. Clause 18 – Modules One, Two and Three: Clause 18(a) and (b); Module Four: Clause 18.
2. Paragraph (a) is without prejudice to rights of data subjects under Regulation (EU) 2016/679.

Clause 4 - Interpretation

1. Where these Clauses use terms that are defined in Regulation (EU) 2016/679, those terms shall have the same meaning as in that Regulation.
2. These Clauses shall be read and interpreted in the light of the provisions of Regulation (EU) 2016/679.
3. These Clauses shall not be interpreted in a way that conflicts with rights and obligations provided for in Regulation (EU) 2016/679.

Clause 5 - Hierarchy

In the event of a contradiction between these Clauses and the provisions of related agreements between the Parties, existing at the time these Clauses are agreed or entered into thereafter, these Clauses shall prevail.

Clause 6 - Description of the transfer(s)

The details of the transfer(s), and in particular the categories of personal data that are transferred and the purpose(s) for which they are transferred, are specified in Annex I.B.

Clause 7 - Docking clause

1. An entity that is not a Party to these Clauses may, with the agreement of the Parties, accede to these Clauses at any time, either as a data exporter or as a data importer, by completing the Appendix and signing Annex I.A.
2. Once it has completed the Appendix and signed Annex I.A, the acceding entity shall become a Party to these Clauses and have the rights and obligations of a data exporter or data importer in accordance with its designation in Annex I.A.
3. The acceding entity shall have no rights or obligations arising under these Clauses from the period prior to becoming a Party.

Section II - Obligations of the Parties

Clause 8 - Data protection safeguards

The data exporter warrants that it has used reasonable efforts to determine that the data importer is able, through the implementation of appropriate technical and organisational measures, to satisfy its obligations under these Clauses. MODULE TWO: Transfer controller to processor

8.1 Instructions

1. The data importer shall process the personal data only on documented instructions from the data exporter. The data exporter may give such instructions throughout the duration of the contract.
2. The data importer shall immediately inform the data exporter if it is unable to follow those instructions.

8.2 Purpose limitation

The data importer shall process the personal data only for the specific purpose(s) of the transfer, as set out in Annex I.B, unless on further instructions from the data exporter.

8.3 Transparency

On request, the data exporter shall make a copy of these Clauses, including the Appendix as completed by the Parties, available to the data subject free of charge. To the extent necessary to protect business secrets or other confidential information, including the measures described in Annex II and personal data, the data exporter may redact part of the text of the Appendix to these Clauses prior to sharing a copy, but shall provide a meaningful summary where the data subject would otherwise not be able to understand its content or exercise his/her rights. On request, the Parties shall provide the data subject with the reasons for the redactions, to the extent possible without revealing the redacted information. This Clause is without prejudice to the obligations of the data exporter under Articles 13 and 14 of Regulation (EU) 2016/679.

8.4 Accuracy

If the data importer becomes aware that the personal data it has received is inaccurate, or has become outdated, it shall inform the data exporter without undue delay. In this case, the data importer shall cooperate with the data exporter to erase or rectify the data.

8.5 Duration of processing and erasure or return of data

Processing by the data importer shall only take place for the duration specified in Annex I.B. After the end of the provision of the processing services, the data importer shall, at the choice of the data exporter, delete all personal data processed on behalf of the data exporter and certify to the data exporter that it has done so, or return to the data exporter all personal data processed on its behalf and delete existing copies. Until the data is deleted or returned, the data importer shall continue to ensure compliance with these Clauses. In case of local laws applicable to the data importer that prohibit return or deletion of the personal data, the data importer warrants that it will continue to ensure compliance with these Clauses and will only process it to the extent and for as long as required under that local law. This is without prejudice to Clause 14, in particular the requirement for the data importer under Clause 14(e) to notify the data exporter throughout the duration of the contract if it has reason to believe that it is or has become subject to laws or practices not in line with the requirements under Clause 14(a).

8.6 Security of processing

1. The data importer and, during transmission, also the data exporter shall implement appropriate technical and organisational measures to ensure the security of the data, including protection against a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access to that data (hereinafter ‘personal data breach’). In assessing the appropriate level of security, the Parties shall take due account of the state of the art, the costs of implementation, the nature, scope, context and purpose(s) of processing and the risks involved in the processing for the data subjects. The Parties shall in particular consider having recourse to encryption or pseudonymisation, including during transmission, where the purpose of processing can be fulfilled in that manner. In case of pseudonymisation, the additional information for attributing the personal data to a specific data subject shall, where possible, remain under the exclusive control of the data exporter. In complying with its obligations under this paragraph, the data importer shall at least implement the technical and organisational measures specified in Annex II. The data importer shall carry out regular checks to ensure that these measures continue to provide an appropriate level of security.
2. The data importer shall grant access to the personal data to members of its personnel only to the extent strictly necessary for the implementation, management and monitoring of the contract. It shall ensure that persons authorised to process the personal data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality.
3. In the event of a personal data breach concerning personal data processed by the data importer under these Clauses, the data importer shall take appropriate measures to address the breach, including measures to mitigate its adverse effects. The data importer shall also notify the data exporter without undue delay after having become aware of the breach. Such notification shall contain the details of a contact point where more information can be obtained, a description of the nature of the breach (including, where possible, categories and approximate number of data subjects and personal data records concerned), its likely consequences and the measures taken or proposed to address the breach including, where appropriate, measures to mitigate its possible adverse effects. Where, and in so far as, it is not possible to provide all information at the same time, the initial notification shall contain the information then available and further information shall, as it becomes available, subsequently be provided without undue delay.
4. The data importer shall cooperate with and assist the data exporter to enable the data exporter to comply with its obligations under Regulation (EU) 2016/679, in particular to notify the competent supervisory authority and the affected data subjects, taking into account the nature of processing and the information available to the data importer.

8.7 Sensitive data

Where the transfer involves personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, or biometric data for the purpose of uniquely identifying a natural person, data concerning health or a person’s sex life or sexual orientation, or data relating to criminal convictions and offences (hereinafter ‘sensitive data’), the data importer shall apply the specific restrictions and/or additional safeguards described in Annex I.B.

8.8 Onward transfers

The data importer shall only disclose the personal data to a third party on documented instructions from the data exporter. In addition, the data may only be disclosed to a third party located outside the European Union (in the same country as the data importer or in another third country, hereinafter ‘onward transfer’) if the third party is or agrees to be bound by these Clauses, under the appropriate Module, or if:

1. the onward transfer is to a country benefitting from an adequacy decision pursuant to Article 45 of Regulation (EU) 2016/679 that covers the onward transfer;
2. the third party otherwise ensures appropriate safeguards pursuant to Articles 46 or 47 of Regulation (EU) 2016/679 with respect to the processing in question;
3. the onward transfer is necessary for the establishment, exercise or defence of legal claims in the context of specific administrative, regulatory or judicial proceedings; or
4. the onward transfer is necessary in order to protect the vital interests of the data subject or of another natural person.

Any onward transfer is subject to compliance by the data importer with all the other safeguards under these Clauses, in particular purpose limitation.

8.9 Documentation and compliance

1. The data importer shall promptly and adequately deal with enquiries from the data exporter that relate to the processing under these Clauses.
2. The Parties shall be able to demonstrate compliance with these Clauses. In particular, the data importer shall keep appropriate documentation on the processing activities carried out on behalf of the data exporter.
3. The data importer shall make available to the data exporter all information necessary to demonstrate compliance with the obligations set out in these Clauses and at the data exporter’s request, allow for and contribute to audits of the processing activities covered by these Clauses, at reasonable intervals or if there are indications of non-compliance. In deciding on a review or audit, the data exporter may take into account relevant certifications held by the data importer.
4. The data exporter may choose to conduct the audit by itself or mandate an independent auditor. Audits may include inspections at the premises or physical facilities of the data importer and shall, where appropriate, be carried out with reasonable notice.
5. The Parties shall make the information referred to in paragraphs (b) and (c), including the results of any audits, available to the competent supervisory authority on request.

Clause 9 - Use of sub-processors

1. GENERAL WRITTEN AUTHORISATION The data importer has the data exporter’s general authorisation for the engagement of sub-processor(s) from an agreed list. The data importer shall specifically inform the data exporter in writing of any intended changes to that list through the addition or replacement of sub-processors at least 14 days in advance, thereby giving the data exporter sufficient time to be able to object to such changes prior to the engagement of the sub-processor(s). The data importer shall provide the data exporter with the information necessary to enable the data exporter to exercise its right to object.
2. Where the data importer engages a sub-processor to carry out specific processing activities (on behalf of the data exporter), it shall do so by way of a written contract that provides for, in substance, the same data protection obligations as those binding the data importer under these Clauses, including in terms of third-party beneficiary rights for data subjects. The Parties agree that, by complying with this Clause, the data importer fulfils its obligations under Clause 8.8. The data importer shall ensure that the sub-processor complies with the obligations to which the data importer is subject pursuant to these Clauses.
3. The data importer shall provide, at the data exporter’s request, a copy of such a sub-processor agreement and any subsequent amendments to the data exporter. To the extent necessary to protect business secrets or other confidential information, including personal data, the data importer may redact the text of the agreement prior to sharing a copy.
4. The data importer shall remain fully responsible to the data exporter for the performance of the sub-processor’s obligations under its contract with the data importer. The data importer shall notify the data exporter of any failure by the sub-processor to fulfil its obligations under that contract.
5. The data importer shall agree a third-party beneficiary clause with the sub-processor whereby – in the event the data importer has factually disappeared, ceased to exist in law or has become insolvent – the data exporter shall have the right to terminate the sub-processor contract and to instruct the sub-processor to erase or return the personal data.

Clause 10 - Data subject rights

1. The data importer shall promptly notify the data exporter of any request it has received from a data subject. It shall not respond to that request itself unless it has been authorised to do so by the data exporter.
2. The data importer shall assist the data exporter in fulfilling its obligations to respond to data subjects’ requests for the exercise of their rights under Regulation (EU) 2016/679. In this regard, the Parties shall set out in Annex II the appropriate technical and organisational measures, taking into account the nature of the processing, by which the assistance shall be provided, as well as the scope and the extent of the assistance required.
3. In fulfilling its obligations under paragraphs (a) and (b), the data importer shall comply with the instructions from the data exporter.

Clause 11 - Redress

1. The data importer shall inform data subjects in a transparent and easily accessible format, through individual notice or on its website, of a contact point authorised to handle complaints. It shall deal promptly with any complaints it receives from a data subject.
2. In case of a dispute between a data subject and one of the Parties as regards compliance with these Clauses, that Party shall use its best efforts to resolve the issue amicably in a timely fashion. The Parties shall keep each other informed about such disputes and, where appropriate, cooperate in resolving them.
3. Where the data subject invokes a third-party beneficiary right pursuant to Clause 3, the data importer shall accept the decision of the data subject to:
   1. lodge a complaint with the supervisory authority in the Member State of his/her habitual residence or place of work, or the competent supervisory authority pursuant to Clause 13;
   2. refer the dispute to the competent courts within the meaning of Clause 18.
4. The Parties accept that the data subject may be represented by a not-for-profit body, organisation or association under the conditions set out in Article 80(1) of Regulation (EU) 2016/679.
5. The data importer shall abide by a decision that is binding under the applicable EU or Member State law.
6. The data importer agrees that the choice made by the data subject will not prejudice his/her substantive and procedural rights to seek remedies in accordance with applicable laws.

Clause 12 - Liability

1. Each Party shall be liable to the other Party/ies for any damages it causes the other Party/ies by any breach of these Clauses.
2. The data importer shall be liable to the data subject, and the data subject shall be entitled to receive compensation, for any material or non-material damages the data importer or its sub-processor causes the data subject by breaching the third-party beneficiary rights under these Clauses.
3. Notwithstanding paragraph (b), the data exporter shall be liable to the data subject, and the data subject shall be entitled to receive compensation, for any material or non-material damages the data exporter or the data importer (or its sub-processor) causes the data subject by breaching the third-party beneficiary rights under these Clauses. This is without prejudice to the liability of the data exporter and, where the data exporter is a processor acting on behalf of a controller, to the liability of the controller under Regulation (EU) 2016/679 or Regulation (EU) 2018/1725, as applicable.
4. The Parties agree that if the data exporter is held liable under paragraph (c) for damages caused by the data importer (or its sub-processor), it shall be entitled to claim back from the data importer that part of the compensation corresponding to the data importer’s responsibility for the damage.
5. Where more than one Party is responsible for any damage caused to the data subject as a result of a breach of these Clauses, all responsible Parties shall be jointly and severally liable and the data subject is entitled to bring an action in court against any of these Parties.
6. The Parties agree that if one Party is held liable under paragraph (e), it shall be entitled to claim back from the other Party/ies that part of the compensation corresponding to its/their responsibility for the damage.
7. The data importer may not invoke the conduct of a sub-processor to avoid its own liability.

Clause 13 - Supervision

1. The supervisory authority with responsibility for ensuring compliance by the data exporter with Regulation (EU) 2016/679 as regards the data transfer, as indicated in Annex I.C, shall act as competent supervisory authority.
2. The data importer agrees to submit itself to the jurisdiction of and cooperate with the competent supervisory authority in any procedures aimed at ensuring compliance with these Clauses. In particular, the data importer agrees to respond to enquiries, submit to audits and comply with the measures adopted by the supervisory authority, including remedial and compensatory measures. It shall provide the supervisory authority with written confirmation that the necessary actions have been taken.

Section III - Local Laws and Obligations in Case of Access by Public Authorities

Clause 14 - Local laws and practices affecting compliance with the Clauses

1. The Parties warrant that they have no reason to believe that the laws and practices in the third country of destination applicable to the processing of the personal data by the data importer, including any requirements to disclose personal data or measures authorising access by public authorities, prevent the data importer from fulfilling its obligations under these Clauses. This is based on the understanding that laws and practices that respect the essence of the fundamental rights and freedoms and do not exceed what is necessary and proportionate in a democratic society to safeguard one of the objectives listed in Article 23(1) of Regulation (EU) 2016/679, are not in contradiction with these Clauses.
2. The Parties declare that in providing the warranty in paragraph (a), they have taken due account in particular of the following elements:
   1. the specific circumstances of the transfer, including the length of the processing chain, the number of actors involved and the transmission channels used; intended onward transfers; the type of recipient; the purpose of processing; the categories and format of the transferred personal data; the economic sector in which the transfer occurs; the storage location of the data transferred;
   2. the laws and practices of the third country of destination – including those requiring the disclosure of data to public authorities or authorising access by such authorities – relevant in light of the specific circumstances of the transfer, and the applicable limitations and safeguards;
   3. any relevant contractual, technical or organisational safeguards put in place to supplement the safeguards under these Clauses, including measures applied during transmission and to the processing of the personal data in the country of destination.
3. The data importer warrants that, in carrying out the assessment under paragraph (b), it has made its best efforts to provide the data exporter with relevant information and agrees that it will continue to cooperate with the data exporter in ensuring compliance with these Clauses.
4. The Parties agree to document the assessment under paragraph (b) and make it available to the competent supervisory authority on request.
5. The data importer agrees to notify the data exporter promptly if, after having agreed to these Clauses and for the duration of the contract, it has reason to believe that it is or has become subject to laws or practices not in line with the requirements under paragraph (a), including following a change in the laws of the third country or a measure (such as a disclosure request) indicating an application of such laws in practice that is not in line with the requirements in paragraph (a).
6. Following a notification pursuant to paragraph (e), or if the data exporter otherwise has reason to believe that the data importer can no longer fulfil its obligations under these Clauses, the data exporter shall promptly identify appropriate measures (e.g. technical or organisational measures to ensure security and confidentiality) to be adopted by the data exporter and/or data importer to address the situation. The data exporter shall suspend the data transfer if it considers that no appropriate safeguards for such transfer can be ensured, or if instructed by the competent supervisory authority to do so. In this case, the data exporter shall be entitled to terminate the contract, insofar as it concerns the processing of personal data under these Clauses. If the contract involves more than two Parties, the data exporter may exercise this right to termination only with respect to the relevant Party, unless the Parties have agreed otherwise. Where the contract is terminated pursuant to this Clause, Clause 16(d) and (e) shall apply.

Clause 15 - Obligations of the data importer in case of access by public authorities

15.1 Notification

1. The data importer agrees to notify the data exporter and, where possible, the data subject promptly (if necessary with the help of the data exporter) if it:
   1. receives a legally binding request from a public authority, including judicial authorities, under the laws of the country of destination for the disclosure of personal data transferred pursuant to these Clauses; such notification shall include information about the personal data requested, the requesting authority, the legal basis for the request and the response provided; or
   2. becomes aware of any direct access by public authorities to personal data transferred pursuant to these Clauses in accordance with the laws of the country of destination; such notification shall include all information available to the importer.
2. If the data importer is prohibited from notifying the data exporter and/or the data subject under the laws of the country of destination, the data importer agrees to use its best efforts to obtain a waiver of the prohibition, with a view to communicating as much information as possible, as soon as possible. The data importer agrees to document its best efforts in order to be able to demonstrate them on request of the data exporter.
3. Where permissible under the laws of the country of destination, the data importer agrees to provide the data exporter, at regular intervals for the duration of the contract, with as much relevant information as possible on the requests received (in particular, number of requests, type of data requested, requesting authority/ies, whether requests have been challenged and the outcome of such challenges, etc.).
4. The data importer agrees to preserve the information pursuant to paragraphs (a) to (c) for the duration of the contract and make it available to the competent supervisory authority on request.
5. Paragraphs (a) to (c) are without prejudice to the obligation of the data importer pursuant to Clause 14(e) and Clause 16 to inform the data exporter promptly where it is unable to comply with these Clauses.

15.2 Review of legality and data minimisation

1. The data importer agrees to review the legality of the request for disclosure, in particular whether it remains within the powers granted to the requesting public authority, and to challenge the request if, after careful assessment, it concludes that there are reasonable grounds to consider that the request is unlawful under the laws of the country of destination, applicable obligations under international law and principles of international comity. The data importer shall, under the same conditions, pursue possibilities of appeal. When challenging a request, the data importer shall seek interim measures with a view to suspending the effects of the request until the competent judicial authority has decided on its merits. It shall not disclose the personal data requested until required to do so under the applicable procedural rules. These requirements are without prejudice to the obligations of the data importer under Clause 14(e).
2. The data importer agrees to document its legal assessment and any challenge to the request for disclosure and, to the extent permissible under the laws of the country of destination, make the documentation available to the data exporter. It shall also make it available to the competent supervisory authority on request.
3. The data importer agrees to provide the minimum amount of information permissible when responding to a request for disclosure, based on a reasonable interpretation of the request.

Section IV - Final Provisions

Clause 16 - Non-compliance with the Clauses and termination

1. The data importer shall promptly inform the data exporter if it is unable to comply with these Clauses, for whatever reason.
2. In the event that the data importer is in breach of these Clauses or unable to comply with these Clauses, the data exporter shall suspend the transfer of personal data to the data importer until compliance is again ensured or the contract is terminated. This is without prejudice to Clause 14(f).
3. The data exporter shall be entitled to terminate the contract, insofar as it concerns the processing of personal data under these Clauses, where:
   1. the data exporter has suspended the transfer of personal data to the data importer pursuant to paragraph (b) and compliance with these Clauses is not restored within a reasonable time and in any event within one month of suspension;
   2. the data importer is in substantial or persistent breach of these Clauses; or
   3. the data importer fails to comply with a binding decision of a competent court or supervisory authority regarding its obligations under these Clauses.
   In these cases, it shall inform the competent supervisory authority of such non-compliance. Where the contract involves more than two Parties, the data exporter may exercise this right to termination only with respect to the relevant Party, unless the Parties have agreed otherwise.
4. Personal data that has been transferred prior to the termination of the contract pursuant to paragraph (c) shall at the choice of the data exporter immediately be returned to the data exporter or deleted in its entirety. The same shall apply to any copies of the data. The data importer shall certify the deletion of the data to the data exporter. Until the data is deleted or returned, the data importer shall continue to ensure compliance with these Clauses. In case of local laws applicable to the data importer that prohibit the return or deletion of the transferred personal data, the data importer warrants that it will continue to ensure compliance with these Clauses and will only process the data to the extent and for as long as required under that local law.
5. Either Party may revoke its agreement to be bound by these Clauses where (i) the European Commission adopts a decision pursuant to Article 45(3) of Regulation (EU) 2016/679 that covers the transfer of personal data to which these Clauses apply; or (ii) Regulation (EU) 2016/679 becomes part of the legal framework of the country to which the personal data is transferred. This is without prejudice to other obligations applying to the processing in question under Regulation (EU) 2016/679.

Clause 17 - Governing law

These Clauses shall be governed by the law of one of the EU Member States, provided such law allows for third-party beneficiary rights. The Parties agree that this shall be the law of Ireland.

Clause 18 - Choice of forum and jurisdiction

1. Any dispute arising from these Clauses shall be resolved by the courts of an EU Member State.
2. The Parties agree that those shall be the courts of Ireland.
3. A data subject may also bring legal proceedings against the data exporter and/or data importer before the courts of the Member State in which he/she has his/her habitual residence.
4. The Parties agree to submit themselves to the jurisdiction of such courts.

Appendix to the Standard Contractual Clauses

Annex I

A. List of Parties

Data exporter(s)	Data importer(s)
Name: The Customer, as identified in the Agreement or applicable order form	Name: Crewfare, Inc, a Delaware corporation
Address: As set out in the Agreement or applicable order form	Address: 2678 Edgewater Court, Weston, Florida 33332, USA
Contact person’s name, position, and contact details: As set out in the Agreement or applicable order form	Contact person’s name, position, and contact details: Jordan Scheffler, Chief Privacy Officer privacy@crewfare.com
Activities relevant to the data transferred under these Clauses: Receipt of the Services described in the Agreement, including submission of reservation, rooming list, and payment method information for the arrangement, management, and fulfillment of accommodation and event travel.	Activities relevant to the data transferred under these Clauses: Provision of the Services described in the Agreement, including travel booking and management software-as-a-service platforms, the Digital Rooming List, transmission of reservation records to accommodation providers, tokenized storage and controlled disclosure of payment method information, customer support, and related services, as further described in Annex 1 to the DPA.
Signature and date: By entering into the Agreement, the data exporter is deemed to have signed these Clauses as of the effective date of the Agreement.	Signature and date: By entering into the Agreement, the data importer is deemed to have signed these Clauses as of the effective date of the Agreement.
Role: Controller (or, where the Customer acts on behalf of a third-party controller, Processor)	Role: Processor

B. Description of Transfer

Categories of data subjects whose personal data is transferred. As set out in Annex 1 to the DPA (Categories of Data Subjects), including individuals named in reservations, rooming lists, and booking records (guests, roommates, event staff, artists, production crew, vendors, and travel contacts); authorized users of the Services; and individuals interacting with customer support. Categories of personal data transferred. As set out in Annex 1 to the DPA (Categories of Personal Data), including personal identification details; employer or organizational affiliation; reservation and stay details; rooming list data; special requests and preferences; payment method information in tokenized form and billing information; account and usage data; communication records; and digital footprint data. Sensitive data transferred (if applicable) and applied restrictions or safeguards. Special requests submitted in connection with a reservation may contain data concerning health, disability, accessibility, or dietary requirements. Applied restrictions and safeguards: strict purpose limitation to fulfilling the request; access restricted to personnel with a documented business need; encryption in transit and at rest; access logging; no use for analytics, profiling, or marketing; onward disclosure only to the accommodation provider fulfilling the request. The frequency of the transfer. Continuous, for the duration of the Agreement. Nature of the processing. Hosting and storage; transmission to accommodation providers; organization and structuring of rooming lists; retrieval and consultation; disclosure by transmission through the Digital Rooming List’s controlled reveal function; erasure and destruction. Purpose(s) of the data transfer and further processing. As set out in Annex 1 to the DPA (Nature and Purpose of Processing): the arrangement, management, and fulfillment of accommodation reservations and event travel; provision of the software-as-a-service platforms; customer support; platform security; service improvement using de-identified or aggregated data; and legal compliance. The period for which the personal data will be retained, or, if that is not possible, the criteria used to determine that period. For the duration of the Agreement plus thirty (30) calendar days, except where longer retention is required by applicable law. Payment card information is purged from the vault thirty (30) days following the later of guest checkout or the applicable event end date, or upon termination of the Agreement, whichever is earlier. For transfers to (sub-) processors, also specify subject matter, nature and duration of the processing. Sub-processors are engaged for cloud hosting and storage, payment processing, payment card vaulting and tokenization, consent management, transactional and marketing email delivery, customer support tooling, project management, analytics, and security monitoring, in each case for the duration of the Agreement. The current list, including each sub-processor’s activity and location, is maintained at https://crewfare.com/gdpr.

C. Competent Supervisory Authority

Where the data exporter is established in an EU Member State, the supervisory authority of that Member State is competent. Where the data exporter is not established in an EU Member State but falls within the territorial scope of the GDPR under Article 3(2) and has appointed a representative under Article 27, the supervisory authority of the Member State in which the representative is established is competent. In all other cases falling within Article 3(2), the competent supervisory authority is the Data Protection Commission of Ireland, 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland. For transfers subject to the UK GDPR, the competent authority is the UK Information Commissioner’s Office.

Annex II

Technical and Organisational Measures Including Technical and Organisational Measures to Ensure the Security of the Data Description of the technical and organisational measures implemented by the data importer:

1. Measures of pseudonymisation and encryption of personal data. All personal data is encrypted in transit using TLS 1.2 or higher and at rest using AES-256. Payment card data is tokenized by a PCI DSS-validated third-party vault provider; Crewfare systems store and transmit only non-sensitive tokens. Card data is rendered to authorized recipients exclusively through vault-hosted browser elements, such that primary account numbers do not transit Crewfare systems.
2. Measures for ensuring ongoing confidentiality, integrity, availability and resilience of processing systems and services. Production infrastructure is hosted on Amazon Web Services with redundancy across availability zones. Role-based access control with least-privilege provisioning; single sign-on and multi-factor authentication enforced for personnel access to production systems; unique authentication for production databases; managed detection and response (MDR) monitoring on endpoints; web application firewall and DDoS protection at the network edge; segregation of production and non-production environments.
3. Measures for ensuring the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident. Automated backups with defined recovery point and recovery time objectives; business continuity and disaster recovery plans established and tested at least annually.
4. Processes for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures. Crewfare maintains a SOC 2 Type II attestation, ISO/IEC 27001:2022 certification, and a PCI DSS 4.0.1 Attestation of Compliance, each renewed on its applicable cycle. Annual third-party penetration testing; continuous automated compliance monitoring; vulnerability scanning with defined remediation SLAs; control self-assessments. Current attestations and certificates are available at https://trust.crewfare.com.
5. Measures for user identification and authorisation. Unique user accounts; enforced password complexity; multi-factor authentication for administrative access; per-use secondary verification (single-use emailed code) for access to payment card data through the reveal function; automatic session expiry; prompt deprovisioning upon role change or departure.
6. Measures for the protection of data during transmission and during storage. As per items 1 and 2 above. Payment card reveal access is additionally scoped to the recipient’s own properties, rate-limited, time-limited to seven days following the applicable event, and logged with user identity and timestamp.
7. Measures for ensuring physical security of locations at which personal data are processed. Personal data is processed in AWS data centers, which maintain physical security controls certified under SOC 2, ISO 27001, and related frameworks. Crewfare offices do not host production data.
8. Measures for ensuring events logging. Centralized logging of authentication events, administrative actions, and access to personal data; immutable audit log of each access to payment card data including accessing user, reservation, and timestamp; log retention consistent with compliance requirements.
9. Measures for ensuring system configuration, including default configuration. Infrastructure as code with peer review; hardened baseline images; change management with approval workflow; asset inventory maintained.
10. Measures for internal IT and IT security governance and management. Documented information security policies reviewed at least annually; designated security function; security awareness training for all personnel at onboarding and annually; confidentiality obligations in all employment agreements; background checks where permitted by law; cybersecurity insurance maintained.
11. Measures for certification/assurance of processes and products. SOC 2 Type II; ISO/IEC 27001:2022; PCI DSS 4.0.1 AoC. See https://trust.crewfare.com.
12. Measures for ensuring data minimisation, data quality, limited data retention, accountability, and data portability and erasure. Collection limited to the categories described in Annex 1; retention and purge schedules as set out in the DPA, including the thirty-day post-termination deletion and the thirty-day payment card purge; customer export functionality for data portability; documented records of processing activities; annual review of the accuracy of the Annexes to the DPA.

For transfers to sub-processors, the data importer imposes contractual obligations substantially equivalent to the measures above and assesses each sub-processor’s security posture prior to engagement and periodically thereafter.

Exhibit 3 - Additional U.S. State Privacy Law Provisions

1. Scope. This Exhibit applies to the extent Company processes Personal Data subject to a U.S. state privacy law, including the California Consumer Privacy Act as amended by the California Privacy Rights Act (“CCPA”), the Virginia Consumer Data Protection Act, the Colorado Privacy Act, the Connecticut Data Privacy Act, and the Utah Consumer Privacy Act (collectively, “US State Privacy Laws”). Terms such as “Business,” “Service Provider,” “Processor,” “Controller,” “Consumer,” “Sell,” and “Share” have the meanings given in the applicable US State Privacy Law.
2. Role of the parties. Customer is a Business or Controller and Company is a Service Provider or Processor with respect to Personal Data processed under the Agreement.
3. Company obligations. Company shall: (a) process Personal Data solely for the Business Purposes described in the Agreement and this DPA, or as otherwise permitted by US State Privacy Laws; (b) not Sell or Share Personal Data; (c) not retain, use, or disclose Personal Data outside of the direct business relationship between the parties or for any purpose other than the Business Purposes, except as permitted by US State Privacy Laws; (d) not combine Personal Data received from Customer with Personal Data received from another source, except as permitted by US State Privacy Laws; (e) comply with applicable obligations under US State Privacy Laws and provide the same level of privacy protection as is required of Customer; (f) notify Customer if it makes a determination that it can no longer meet its obligations under US State Privacy Laws; and (g) grant Customer the right, upon notice, to take reasonable and appropriate steps to stop and remediate unauthorized use of Personal Data.
4. Assistance and subcontracting.
   1. Company shall provide reasonable assistance to Customer in responding to verifiable Consumer requests under US State Privacy Laws, taking into account the nature of the processing.
   2. Company shall promptly forward to Customer any Consumer request it receives directly that relates to Personal Data processed on Customer’s behalf, and shall not respond to such request except on Customer’s documented instructions or as required by law.
   3. Company’s current subcontractors and sub-processors are viewable at https://crewfare.com/gdpr. Company shall provide notice of any new subcontractor or sub-processor in accordance with the Subprocessing section of this DPA.
   4. Customer may object to a new subcontractor or sub-processor within thirty (30) days of notice, in which case the parties shall proceed as set out in the Subprocessing section of this DPA.
5. Audit. Customer may, upon reasonable notice and no more than once annually (except following a Personal Data Breach or a determination under Section 3(f)), audit Company’s compliance with this Exhibit through the audit mechanism set out in the Audit Rights section of this DPA.
6. Deidentified data. To the extent Company receives or creates deidentified data, Company shall: (a) take reasonable measures to ensure the information cannot be associated with a Consumer or household; (b) publicly commit to maintain and use the information in deidentified form and not attempt to reidentify it, except as permitted to test the effectiveness of deidentification; and (c) contractually obligate any recipients to comply with the foregoing.

End of Data Processing Addendum.