Last Updated: July 30, 2024

Effective Date: August 1, 2024

This Data Processing Addendum (“DPA”) is a part of, and fully incorporated into, the Master Services Agreement (the “MSA”) between you and Wowo Sim. It becomes effective as soon as you use any Wowo Sim service (the “Effective Date”). Any capitalized terms not specifically defined in this DPA will have the same meaning as in the MSA.

Definitions

Key terms used in this DPA are defined in the section they first appear or as follows:

• Covered Data Breach: A breach in Wowo Sim’s security systems that results in the unintended loss or unauthorized disclosure of Covered PII on systems under Wowo Sim’s control. This does not apply to breaches caused by negligence or intentional acts by any user.
• Covered PII: Any Personal Identifiable Information (PII) processed through Wowo Sim’s services.
• Data Subject: An individual who can be identified either directly or indirectly through personal data, such as an identification number or other factors linked to their identity (e.g., cultural, physical, or social identity).
• Personal Identifiable Information (PII): Information that identifies or relates to a specific individual, excluding data that is publicly available, anonymized, or aggregated.

Instructions for Processing

You instruct Wowo Sim to process Covered PII in line with this agreement. If you need Wowo Sim to process data in a way that is not aligned with the standard terms, you must provide a written notice at least 30 days in advance. It is your responsibility to ensure your instructions comply with applicable laws and the terms of this DPA.

Authority of Wowo Sim

Wowo Sim may process your Covered PII as instructed, provided that:

• Wowo Sim implements and maintains technical and organizational measures to protect PII as required by this DPA.
• Wowo Sim may engage third-party service providers (TSPs) to process Covered PII, but only after ensuring compliance with relevant laws.
• In the case of a Covered Data Breach, Wowo Sim will notify you promptly and provide necessary information to help you meet any data breach notification requirements.

General Processing of PII

Wowo Sim will process Covered PII solely to provide services to you, as permitted by the terms of service. Wowo Sim will not disclose or transfer your Covered PII to any third party, except:

• To a Wowo Sim representative or TSP that agrees to the terms of this DPA; or
• As required by law.

Processing European Covered PII

This section applies if Wowo Sim processes PII from European countries under GDPR regulations:

• GDPR Compliance: Wowo Sim will comply with the General Data Protection Regulation (GDPR) for all PII originating from the European Union.
• Wowo Sim is a Data Processor, processing data on your behalf as the Data Controller.
• If you or your users require Wowo Sim to process European PII, you must review and consent to the EU Model Contract, which governs data transfers from the EU.

Processing California Covered PII

This section applies if Wowo Sim processes PII from California residents under CCPA regulations:

• CCPA Compliance: Wowo Sim will comply with the California Consumer Privacy Act (CCPA).
• You, as the Data Controller, oversee and are responsible for California PII, while Wowo Sim acts as a Data Processor.
• Wowo Sim will process California Covered PII only as instructed in this DPA and maintain the confidentiality of this data.

End-User Data Relationships

Wowo Sim does not have a direct legal or transactional relationship with your end-users. All interactions between Wowo Sim and your end-users are mediated by you, the service customer.

Conditions of Use

Both parties agree to abide by GDPR, CCPA, or other relevant laws regarding the processing of personal data. Upon termination of services, Wowo Sim will either delete, return, or securely retain PII as permitted by law.

Amendments and Conflicts

This DPA amends the Master Services Agreement specifically with respect to data processing. In the case of any conflict between this DPA and other agreements, this DPA will prevail.