Data Processing Addendum

ATONOM DATA PROCESSING ADDENDUM

Last updated: March 10, 2026

THIS DATA PROCESSING ADDENDUM ("DPA") supplements the Agreement(s) (as defined below) entered by and between Atonom and Customer. Customer is entering into this DPA on behalf of itself and its Authorized Affiliates, if applicable. All references herein to Customer also apply to Customer's Authorized Affiliates. Capitalized terms not defined in this DPA shall be as defined in the Agreement or Applicable Data Protection Laws.

1. Definitions

"Authorized Persons" means those Atonom employees, agents, Sub-Processors, and contractors that have a need to know or otherwise access Customer Data to enable Atonom to provide the Services.

"CCPA" means the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, together with any implementing regulations, as may be amended or superseded from time to time, and applicable implementing regulations.

"CCPA Addendum" means the terms set forth in Annex A to this DPA which are incorporated into this DPA and the Agreement(s).

"Controller" means a controller as defined under the GDPR.

"Customer Data" means all data relating to a User that is (i) provided to Atonom by Customer or a User or (ii) otherwise obtained, accessed, developed, or produced by Atonom on behalf of Customer. Customer Data may include Personal Data.

"Data Protection Laws" means all applicable federal, state, and foreign data protection, privacy and data security laws, as well as applicable regulations and formal directives intended by their nature to have the force of law, including, without limitation, the EU Data Protection Laws, UK Data Protection Laws, and the CCPA, but excluding consent decrees.

"Security Incident" means any loss or unauthorized access, acquisition, theft, destruction, disclosure or use of Customer Data that occurs while such Customer Data is in the possession of or under the control of Atonom.

"Data Subject" means the identified or identifiable person to whom Personal Data relates.

"EU Data Protection Laws" means all laws and regulations of the European Union, the European Economic Area, their member states, and Switzerland applicable to the processing of Personal Data for the services under the Agreement, including, where applicable, the GDPR.

"UK Data Protection Laws" means all laws and regulations of the United Kingdom applicable to the processing of Personal Data for the services under the Agreement.

EU Data Protection Laws and UK Data Protection Laws may be collectively referred to as International Data Protection Laws.

"GDPR" means the EU General Data Protection Regulation 2016/679, including as implemented or adopted under the laws of the United Kingdom.

"Personal Data" means information relating to an identified or identifiable natural person. An identifiable natural person is a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

"Process" or "Processing" means any operation or set of operations that are performed upon Customer Data, whether or not by automatic means, such as collection, accessing, processing, use, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure, dissemination, transmittal, alignment or combination, blocking, erasure, destruction or otherwise used as set out in the applicable Data Protection Laws.

"Processor" means a processor as defined under the GDPR, including any applicable "service provider" as that term is defined under the CCPA.

"Services" means Atonom's services, solutions and products.

"Standard Contractual Clauses" means Standard Contractual Clauses for the transfer of Personal Data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and the Council approved by European Commission Implementing Decision (EU) 2021/914 of 4 June 2021, as currently set out at https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj.

"Sub-Processor" shall mean a Processor engaged by Atonom to assist it in Processing the Customer Data in fulfilment of Atonom's obligations with regard to the Services.

"Third Party" is any person or entity other than Atonom and Customer and Customer's Users.

"User" is a person who is affiliated with Customer or is a customer of Customer and is a user of Atonom's Services.

2. Data Processing

2.1 Scope and Roles of the Parties. This DPA applies when Personal Data included in Customer Data is processed by Atonom. The Parties shall comply with their obligations under all Data Protection Laws. For purposes of the GDPR, if Customer is the Controller then Atonom is its Processor; if Customer is a Processor, then Atonom is its Sub-Processor. For purposes of the CCPA, Atonom is a Service Provider as that term is defined by the CCPA.

2.2 Customer's Processing of Personal Data. Customer shall, in its use of the Services, Process Personal Data in accordance with the requirements of applicable Data Protection Laws, including any applicable requirement to provide notice to Data Subjects of Customer's use of Atonom as Processor, including where the Customer is a Processor, by ensuring that the ultimate Controller does so. For the avoidance of doubt, Customer's instructions for the Processing of Personal Data shall comply with applicable Data Protection Laws. Customer shall have sole responsibility for the accuracy, quality, and legality of Personal Data and the means by which Customer acquired Personal Data. Customer specifically acknowledges and agrees that it is responsible for ensuring, and shall ensure, its use of the Services will not and do not violate the rights of any Data Subject, including those Data Subjects that have opted out from sales or other disclosures of Personal Data, to the extent applicable under relevant Data Protection Laws.

2.3 Atonom's Processing of Personal Data. Atonom shall treat Personal Data as Confidential Information and shall Process Personal Data on behalf of and only in accordance with Customer's documented instructions for the following purposes: (i) Processing in accordance with the Agreement and applicable Service Order(s); (ii) Processing initiated by Users in their use of the Services; and (iii) Processing to comply with other documented reasonable instructions provided by Customer, for example via email, where such instructions are consistent with the terms of the Agreement. For the avoidance of doubt, Atonom shall comply with all applicable provisions of, and is prohibited from selling or sharing Personal Data in contravention of the requirements of, the CCPA.

2.4 Details of the Processing. The subject matter of Processing of Personal Data by Atonom is the performance of the Services pursuant to the Agreements. The duration of the Processing, the nature and purpose of the Processing, the types of Personal Data and categories of Data Subjects Processed under this DPA are further specified in Schedule 2 (Description of Processing/Transfer) to this DPA.

2.5 Data Minimization and Sensitive Personal Data. Customer and Users should provide Atonom only with Personal Data that is requested by Atonom on behalf of Customer or that is otherwise necessary for Atonom to provide the Services. Atonom is not responsible for any other Personal Data. Customer represents and warrants that it has obtained all necessary consents from all Users to provide their Personal Data to Atonom. Customer and Users are advised not to provide Atonom with Sensitive Personal Data (as defined under Applicable Data Protection Laws).

2.6 Sub-Processors. Atonom may engage Sub-Processors in connection with the provision of the Services, provided, however, that Atonom may not provide a Sub-Processor with access to Personal Data unless the Sub-Processor has: (i) a business need to know or access the relevant Personal Data, as necessary for the purposes of the Services; (ii) signed a written obligation of confidentiality or is under professional obligations of confidentiality; and (iii) implemented technical, operational, physical, and organizational safeguards to protect Personal Data against accidental or unlawful destruction or alteration and unauthorized disclosure or access. Atonom shall be responsible for the acts and omissions of its Sub-Processors for breaches of Atonom's obligations in relation to the Processing of any Personal Data as though they were the acts or omissions of Atonom. Atonom shall give Customer notice of the appointment of any new Sub-Processor at a URL provided to Customer or via notice either in the Services or via email. If, within thirty (30) days of receipt of that notice, Customer notifies Atonom in writing of any reasonable objection to the proposed appointment based on reasonable data protection grounds, the Parties shall negotiate in good faith a mutually acceptable alternative. If no such alternative is agreed within sixty (60) days of the objection, Customer will have the right to terminate the applicable Service Order to the extent it relates to services which require use of the proposed Sub-Processor.

2.7 Data Subject Rights; Cooperation. Atonom shall use commercially reasonable efforts to cooperate and assist with a Data Subject's exercise of his or her rights under applicable Data Protection Laws with respect to Personal Data Processed by Atonom, including, without limitation, the right to be forgotten, the right to data portability, and the right to access data under Applicable Data Protection Laws. Upon Customer's request, Atonom shall provide Customer with reasonable assistance needed to fulfill Customer's obligation under applicable Data Protection Laws 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 Atonom.

2.8 Return or Destruction of Customer Data. Upon the written request of a Data Subject, Atonom will notify Customer and, upon receipt of instructions from Customer, will promptly return Personal Data to the Data Subject in a commonly readable format or securely delete Personal Data as soon as reasonably practicable.

3. Data Security

3.1 Security Program Requirements. Atonom will maintain a security program that contains administrative, technical, and physical safeguards appropriate to the complexity, nature, and scope of its activities. Atonom's security program shall be designed to protect the security and confidentiality of Personal Data against unlawful or accidental access to, or unauthorized processing, disclosure, destruction, damage or loss of Personal Data. At a minimum, Atonom's security program shall include: (a) limiting access of Personal Data to Authorized Persons; (b) implementing network, application, database, and platform security; (c) means for securing information transmission, storage, and disposal within Atonom's possession or control; (d) means for encrypting Personal Data stored on media within Atonom's possession or control by using modern acceptable ciphers and key lengths, including backup media; (e) means for encrypting Personal Data transmitted by Atonom over public or wireless networks by using modern acceptable ciphers and key lengths; and (f) means for keeping firewalls, routers, servers, personal computers, and all other resources current with appropriate security-specific system patches.

3.2 Regular Reviews. Atonom shall ensure that its security measures are regularly reviewed and revised to address evolving threats and vulnerabilities. Atonom shall maintain an audit program to help ensure adherence with the obligations set forth in this DPA.

3.3 Audit Rights. Customer may contact Atonom to request an audit of Atonom's Processing activities covered by this DPA ("Audit"). An Audit may be conducted by Customer either itself or through a Third-Party auditor selected by Customer when:

(i) the information available from third-party certifications and audits is not sufficient to demonstrate compliance with the obligations set out in this DPA and its Schedules;

(ii) Customer has received a notice from Atonom of a Security Incident; or

(iii) such an audit is required by Data Protection Laws or by Customer's competent supervisory authority.

Any Audits will be limited to no more than once per year, and shall only be of applicable Personal Data processing and storage facilities operated by Atonom or any of Atonom's Affiliates where Customer's Personal Data is processed. Customer acknowledges that Atonom operates a multi-tenant cloud environment. Accordingly, Atonom shall have the right to reasonably adapt the scope of any Audit to avoid or mitigate risks with respect to, and including service levels, availability, and confidentiality of other Atonom clients' information.

4. Security Incident Procedures

4.1 Notification. Atonom shall notify Customer and any affected User of any Security Incident as soon as practicable and without undue delay after becoming aware of it and in any case not later than within 48 hours. Such notification shall at a minimum: (i) describe the nature of the Security Incident, the categories and numbers of Users concerned, and the categories and numbers of Personal Data records concerned; (ii) communicate the name and contact details of Atonom's data protection officer or other relevant contact from whom more information may be obtained; and (iii) describe the measures taken or proposed to be taken to address the Security Incident.

4.2 Remedial Actions. In the event of a Security Incident for which Atonom is responsible, Atonom will use commercially reasonable efforts to: (a) remedy the Security Incident condition, investigate, document, restore the Services, and undertake legally required response activities; (b) provide regular status reports to Customer on Security Incident response activities; (c) assist Customer with the coordination of media, law enforcement, or other Security Incident notifications; and (d) assist and cooperate with Customer in its Security Incident response efforts.

5. Cross-Border Transfers

5.1 Location. Atonom systems and Atonom's Processing of Customer Data will occur within the following jurisdictions: United States of America (the "Processing Jurisdictions"). Atonom will not transfer any Customer Data outside of the Processing Jurisdictions except as directed by or with the consent of Customer and/or User. To the extent that Atonom is a recipient of Personal Data protected by the GDPR, Atonom agrees to abide by and Process such Personal Data in compliance with the Standard Contractual Clauses, which are incorporated into this Addendum, to enable the lawful transfer of EU Personal Data.

5.2 Sub-Processors. Before providing Customer Data of a European or a UK citizen (for purposes of this DPA, "European" shall include the European Union, the European Economic Area, Switzerland and "UK" shall refer to the United Kingdom) to Sub-Processors, Atonom will use commercially reasonable efforts to ensure that the Sub-Processors will enter into a Data Protection Agreement which incorporates Standard Contractual Clauses. Any indemnification and/or limitation of liability obligations of the parties are as set forth in the Agreement(s).

Schedule 1 – Transfer Mechanisms for European Data Transfers

STANDARD CONTRACTUAL CLAUSES OPERATIVE PROVISIONS AND ADDITIONAL TERMS

For the purposes of the European Union Controller to Processor Transfer Clauses (hereinafter, "EU C-to-P Transfer Clauses") and the European Union Processor to Processor Transfer Clauses (hereinafter, "EU P-to-P Transfer Clauses"), Customer is the data exporter and Atonom is the data importer and the Parties agree to the following. If and to the extent an Authorized Affiliate relies on the EU C-to-P Transfer Clauses or the EU P-to-P Transfer Clauses for the transfer of Personal Data, any references to "Customer" in this Schedule include such Authorized Affiliate. Where this Section 1 does not explicitly mention EU C-to-P Transfer Clauses or EU P-to-P Transfer Clauses, it applies to both of them.

1.1 Reference to the Standard Contractual Clauses. The relevant provisions contained in the Standard Contractual Clauses are incorporated by reference and are an integral part of this DPA. The information required for the purposes of the Appendix to the Standard Contractual Clauses are set out in Schedule 2.

1.2 Docking Clause. The option under Clause 7 shall not apply.

1.3 Instructions. This DPA and the Agreement are Customer's complete and final documented instructions at the time of signature of the Agreement to Atonom for the Processing of Personal Data. Any additional or alternate instructions must be consistent with the terms of this DPA and the Agreement. For the purposes of Clause 8.1(a), the instructions by Customer to Process Personal Data are set out in Section 2.3 of this DPA and include onward transfers to a third party located outside Europe for the purpose of the performance of the Services.

1.4 Certification of Deletion. The parties agree that the certification of deletion of Personal Data that is described in Clauses 8.5 and 16(d) of the Standard Contractual Clauses shall be provided by Atonom to Customer upon Customer's written request.

1.5 Security of Processing. For the purposes of Clause 8.6(a), Customer is solely responsible for making an independent determination as to whether the technical and organizational measures set forth in Atonom's security documentation meet Customer's requirements and agrees that, taking into account the state of the art, the costs of implementation, and the nature, scope, context and purposes of the Processing of its Personal Data as well as the risks to individuals, the security measures and policies implemented and maintained by Atonom provide a level of security appropriate to the risk with respect to its Personal Data. For the purposes of Clause 8.6(c), personal data breaches will be handled in accordance with this DPA.

1.6 Audits of the SCCs. The parties agree that the audits described in Clause 8.9 of the Standard Contractual Clauses shall be carried out in accordance with this DPA.

1.7 General Authorization for Use of Sub-Processors. Option 2 under Clause 9 shall apply. For the purposes of Clause 9(a), Atonom has Customer's general authorization to engage Sub-Processors in accordance with this DPA. Atonom shall make available to Customer the current list of Sub-Processors. Where Atonom enters into the EU P-to-P Transfer Clauses with a Sub-processor in connection with the provision of the Services, Customer hereby grants Atonom authority to provide a general authorization on Controller's behalf for the engagement of sub-processors by Sub-processors engaged in the provision of the Services, as well as decision making and approval authority for the addition or replacement of any such sub-processors.

1.8 Notification of New Sub-Processors and Objection Right for New Sub-Processors. Pursuant to Clause 9(a), Customer acknowledges and expressly agrees that Atonom may engage new Sub-Processors as described in Section 3 of this DPA. Atonom shall inform Customer of any changes to Sub-Processors following the procedure provided in this DPA. A list of such Sub-Processors is included at Exhibit A, attached hereto and made a part hereof.

1.9 Complaints – Redress. For the purposes of Clause 11, and subject to this DPA, Atonom shall inform Data Subjects on its website of a contact point authorized to handle complaints. Atonom shall inform Customer if it receives a complaint by, or dispute from, a Data Subject with respect to Personal Data and shall without undue delay communicate the complaint or dispute to Customer. Atonom shall not otherwise have any obligation to handle the request unless otherwise agreed with Customer. The option under Clause 11 shall not apply.

1.10 Liability. Atonom's liability under Clause 12(b) shall be limited by the Agreements and also limited to any damage caused by its Processing where Atonom has not complied with its obligations under the GDPR specifically directed to Processors, or where it has acted outside of or contrary to lawful instructions of Customer, as specified in Article 82 GDPR.

1.11 Supervision. Clause 13 shall apply as follows:

Where Customer is not established in an EU Member State, but falls within the territorial scope of application of Regulation (EU) 2016/679 in accordance with its Article 3(2) and has appointed a representative pursuant to Article 27(1) of Regulation (EU) 2016/679, the supervisory authority of the Member State in which the representative within the meaning of Article 27(1) of Regulation (EU) 2016/679 is established shall act as competent supervisory authority.

Where Customer is established in the United Kingdom or falls within the territorial scope of application of the Data Protection Laws and Regulations of the United Kingdom ("UK Data Protection Laws and Regulations"), the Information Commissioner's Office ("ICO") shall act as competent supervisory authority.

Where Customer is established in Switzerland or falls within territorial scope of application of the Data Protection Laws and Regulations of Switzerland ("Swiss Data Protection Laws and Regulations"), the Swiss Federal Data Protection and Information Commissioner shall act as competent supervisory authority insofar as the relevant data transfer is governed by Swiss Data Protection Laws and Regulations.

1.12 Notification of Government Access Requests. For the purposes of Clause 15(1)(a), Atonom shall notify Customer only, and not the Data Subject(s), in case of government access request. Customer shall be solely responsible for promptly notifying the Data Subject as necessary.

1.13 Governing Law. The governing law for the purposes of Clause 17 shall be the law that is designated in the governing law section of the Agreement. If the Agreement is not governed by an EU Member State law, the Standard Contractual Clauses will be governed by either (i) the laws of Ireland; or (ii) where the Agreement is governed by the laws of the United Kingdom, the laws of England and Wales.

1.14 Choice of Forum and Jurisdiction. The courts under Clause 18 shall be those designated in the venue section of the Agreement. If the Agreement does not designate an EU Member State court as having exclusive jurisdiction to resolve any dispute or lawsuit arising out of or in connection with this Agreement, the parties agree that the courts of either (i) Ireland; or (ii) where the Agreement designates the United Kingdom as having exclusive jurisdiction, the courts of England and Wales shall have exclusive jurisdiction to resolve any dispute arising from the Standard Contractual Clauses. For Data Subjects habitually resident in Switzerland, the courts of Switzerland are an alternative place of jurisdiction in respect of disputes.

1.15 Appendix. The Appendix shall be completed as follows:

The contents of Section 1 of Schedule 2 shall form Annex I.A to the Standard Contractual Clauses.

The contents of Sections 2 to 5 of Schedule 2 shall form Annex I.B to the Standard Contractual Clauses.

The contents of Section 6 of Schedule 2 shall form Annex II to the Standard Contractual Clauses.

1.16 Data Exports from the United Kingdom under the Standard Contractual Clauses. For data transfers governed by UK Data Protection Laws, the Mandatory Clauses of the Approved Addendum, being the template Addendum B.1.0 issued by the ICO and laid before Parliament in accordance with Section 119A of the Data Protection Act 2018 on 2 February 2022, as revised under Section 18 of those Mandatory Clauses ("Approved Addendum"), shall apply. The information required for Tables 1 to 3 of Part One of the Approved Addendum is set out in Schedule 2 of this DPA, as applicable. For the purposes of Table 4 of Part One of the Approved Addendum, neither party may end the Approved Addendum when it changes. In such case, the Parties shall assess whether international transfers of Personal Data are still needed and shall agree, as the case may be, on the appropriate legal mechanism to ensure transfers in accordance with all applicable Data Protection Laws.

1.17 Data Exports from Switzerland under the Standard Contractual Clauses. For data transfers governed by Swiss Data Protection Laws, the Standard Contractual Clauses also apply to the transfer of information relating to an identified or identifiable legal entity where such information is protected similarly as Personal Data under Swiss Data Protection Laws until such laws are amended to no longer apply to a legal entity. However, in respect of any data transfer(s) originating from Switzerland, the approved EU SCCs shall be modified in accordance with the statement of the Swiss Federal Data Protection and Information Commissioner ("FDPIC") of 27 August 2021, available at: https://www.edoeb.admin.ch/dam/edoeb/en/dokumente/2021/Paper%20SCC%20def.en%2024082021.pdf.download.pdf/Paper%20SCC%20def.en%2024082021.pdf. In particular: the FDPIC shall be the competent supervisory authority insofar as the data transfer is governed by the Swiss Federal Act on Data Protection ("FADP") with parallel supervision together with the EU competent supervisory authority (Clause 13); the law of the EU country specified by the Clauses shall be the governing law (Clause 17); the courts of the EU country as specified by the Clauses shall be the choice of forum (Clause 18), but this shall not exclude individuals in Switzerland from the possibility of bringing a claim in their place of habitual residence in Switzerland, in accordance with Clause 18(c). The parties agree to adjust the protection of the Personal Data upon entry into force of the revised FADP.

1.18 Conflict. The Standard Contractual Clauses are subject to this DPA and the additional safeguards set out hereunder. The rights and obligations afforded by the Standard Contractual Clauses will be exercised in accordance with this DPA, unless stated otherwise. In the event of any conflict or inconsistency between the body of this DPA and the Standard Contractual Clauses, the Standard Contractual Clauses shall prevail.

Additional Terms for the EU P-to-P Transfer Clauses

For the purposes of the EU P-to-P Transfer Clauses only, the Parties agree the following.

Instructions and Notifications. For the purposes of Clause 8.1(a), Customer hereby informs Atonom that it acts as Processor under the instructions of the relevant Controller in respect of Personal Data. Customer warrants that its Processing instructions as set out in the Agreement and this DPA, including its authorizations to Atonom for the appointment of Sub-processors in accordance with this DPA, have been authorized by the relevant Controller. Customer shall be solely responsible for forwarding any notifications received from Atonom to the relevant Controller where appropriate.

Security of Processing. For the purposes of Clauses 8.6(c) and (d), Atonom shall provide notification of a personal data breach concerning Personal Data Processed by Atonom to Customer.

Documentation and Compliance. For the purposes of Clause 8.9, all inquiries from the relevant Controller shall be provided to Atonom by Customer. If Atonom receives an inquiry directly from a Controller, it shall forward the inquiry to Customer and Customer shall be solely responsible for responding to any such inquiry from the relevant Controller where appropriate.

Data Subject Rights. For the purposes of Clause 10 and subject to Section 3 of this DPA, Atonom shall notify Customer about any request it has received directly from a Data Subject without obligation to handle it, unless otherwise agreed, but shall not notify the relevant Controller. Customer shall be solely responsible for cooperating with the relevant Controller in fulfilling the relevant obligations to respond to any such request.

Schedule 2 – Description of Processing/Transfer

This Schedule forms part of the Clauses. The Member States may complete or specify, according to their national procedures, any additional necessary information to be contained in this Appendix.

1. List of Parties

Data Exporter. The data exporter is the entity identified as "Customer" in the DPA.

Data Importer. The data importer is the entity identified as "Atonom" in the DPA.

2. Subject Matter and Duration of the Processing of Customer Personal Data. The subject matter, nature, purpose and duration of the processing of the Customer Personal Data are set out in the Agreements and as may be further stated below or elsewhere in this DPA.

3. Data Subjects. The Customer Personal Data transferred to Processor is determined and controlled by Customer in its sole discretion.

4. Categories of Data. The personal data transferred to or accessed by Processor includes all relevant information required to deliver requested services under the Agreement, is determined and controlled by Customer in its sole discretion, and may include:

• Personal details such as first and last name, email address, telephone number and physical address
• Authentication credentials to use part of the services, such as username, IP address, PC name, etc.
• Activities performed by Controller personnel, its agents, contractors or affiliates as users of the performed Services
• Any other category of data agreed upon between the Parties in an Agreement and as otherwise necessary to carry out the services contemplated by the Agreements

5. Special Categories of Data (if appropriate). The Customer Personal Data may concern the following special categories of data: None.

6. Processing Operations. Personal data will be processed for the purpose of and to the extent necessary for the performance of the Services requested from Customer under the Agreement only and will be subject to the basic processing activities set out in the DPA for the performance of Services.

7. Description of the Technical and Organizational Security Measures Implemented by the Data Importer in Accordance with Clauses 4(d) and 5(c). Data importer has implemented appropriate technical and organizational security measures to ensure a level of security appropriate to the risks that are presented by the processing and the nature of the Personal Data to be protected, which shall be at least equivalent to those described in the Addendum. Processor will also adhere to the procedures and requirements set forth in its Privacy Policy set forth at https://atonom.ai/privacy-policy.

EXHIBIT A to DPA

ATONOM SUB-PROCESSORS

A current list of Atonom Sub-processors can be found at: https://app.atonom.ai/#/settings/sub-processors

EXHIBIT B to DPA

CCPA Addendum

This CCPA Addendum supplements the Agreements (including the DPA) between the Parties when the California Consumer Privacy Act of 2018, as amended, including as amended by the CCPA, applies to Customer's and its Users' use of the Services to process personal information that is uploaded to the Services. For purposes of this CCPA Addendum, "commercial purpose," "personal information," "process," "sell," and "share" shall have the meaning ascribed to them in the CCPA. Unless otherwise defined in this CCPA Addendum, all capitalized terms will have the meanings given to them in the Agreement(s).

Atonom agrees that Atonom will: (a) process Personal Information pursuant to the Agreement(s) for the purposes specified in Section 2 of the DPA; (b) not retain, use, or disclose Personal Information for any purpose, including any commercial purpose, except as permitted in the Agreement(s) or under the CCPA; (c) not retain, use, or disclose Personal Information outside the direct business relationship between Atonom and Customer, including by not combining any Personal Information with other personal information collected or received from another source, except as permitted by the CCPA; and (d) not sell or share Personal Information except as permitted by the CCPA. Atonom will inform Customer if it determines that it can no longer meet its obligations under the CCPA. If Atonom is engaged in unauthorized use of Personal Information, Customer may, upon reasonable notice to Atonom, take reasonable and appropriate steps to stop and remediate the unauthorized use of Personal Information. This CCPA Addendum does not limit or reduce any other data privacy commitments Atonom makes to Customer in the Agreement(s).