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Legal

Data Processing Addendum

Effective: 2026-05-01

DRAFT — REQUIRES LEGAL REVIEW. This document is a working draft and must be reviewed by qualified counsel before publication.

This Data Processing Addendum ("DPA") supplements the Talarity Terms of Service and applies to processing of personal data on behalf of customers subject to GDPR, UK GDPR, or comparable data-protection laws.

1. Definitions

"Personal Data," "Processing," "Data Subject," "Controller," and "Processor" have the meanings given in Article 4 of GDPR.

2. Roles

For Customer Content uploaded to the Service, the customer is the Controller and Talarity is the Processor.

3. Processing instructions

Talarity processes Personal Data only on documented instructions from the customer, including in the Service's published features and contracted services.

4. Confidentiality

Talarity ensures personnel authorized to process Personal Data are bound by confidentiality obligations.

5. Security

Talarity implements appropriate technical and organizational measures, summarized at our Trust Center and detailed in /legal/security.

6. Sub-processors

The customer authorizes Talarity to engage sub-processors listed at /legal/sub-processors. Talarity will notify customers of changes at least 30 days in advance and offer a right to object.

7. Data subject rights

Talarity will provide reasonable assistance to the customer in responding to data subject requests, taking into account the nature of processing.

8. Breach notification

Talarity will notify customers without undue delay (and in any event within 72 hours where required by law) after becoming aware of a Personal Data Breach affecting their data.

9. International transfers

For transfers from the EEA, UK, or Switzerland to the United States, Talarity relies on Standard Contractual Clauses (SCCs) and the UK International Data Transfer Addendum where applicable.

10. Audit rights

Talarity will make available information necessary to demonstrate compliance with this DPA and allow for and contribute to audits, including inspections, conducted by the customer or its mandated auditor, subject to reasonable confidentiality and operational constraints.

11. Termination

On termination of the Service, Talarity will delete or return Personal Data per the Terms of Service (60-day export window, then deletion).

12. Execution

A signed copy of this DPA is available on request. Email legal@talarity.com.