Meedan Data Processing Agreement

Last modified
March 30, 2026

This Meedan Data Processing Agreement and its annexes (“DPA”) reflect the Parties’ agreement with respect to the Processing of Personal Data by Meedan Inc. (“us” or “we”) on behalf of Company (“you”) in connection with the agreement or terms of service (each, the “Agreement”) under which we have agreed to provide you with certain Services (the “Meedan Services”). Terms used but not otherwise defined in this DPA will have the meaning as set forth in the Agreement.

This DPA is supplemental to, and forms an integral part of, the Agreement and is effective upon its incorporation into the Agreement, which may be specified in the Agreement, an Order Form or an executed amendment to the Agreement. In case of any conflict or inconsistency with the terms of the Agreement, this DPA will take precedence over the terms of the Agreement to the extent of such conflict or inconsistency.

We update these terms from time to time. If you have any active Meedan Services, we will let you know when we do via email. 

The term of this DPA will follow the term of the Agreement. 

  • Definitions
  • User Responsibilities
  • Meedan Obligations
  • Data Subject Requests
  • Sub-Processors
  • Data Transfers
  • Additional Provisions for Data Processing
  • General Provisions
  • Parties to this DPA

Annex 1 - Details of Processing
Annex 2 - Security Measures

1. Definitions

“California Personal Information” means Personal Data that is subject to the protection of the CCPA.
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“CCPA” means California Civil Code Sec. 1798.100 et seq. (also known as the California Consumer Privacy Act of 2018).
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“Business” and “Service Provider” will have the meanings given to them in the CCPA. 
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“Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the Processing of Personal Data.
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“Data Protection Laws” means all applicable worldwide legislation relating to data protection and privacy which applies to the respective party in the role of Processing Personal Data in question under the Agreement, including without limitation European Data Protection Laws and the CCPA; in each case as amended, repealed, consolidated or replaced from time to time. 
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“Data Subject” means the individual to whom Personal Data relates.
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“Europe” means the European Union, the European Economic Area and/or their member states, Switzerland and the United Kingdom. 
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“European Data” means Personal Data that is subject to the protection of European Data Protection Laws.
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“European Data Protection Laws” means data protection laws applicable in Europe, including: (i) Regulation 2016/679 of the European Parliament and of the Council 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) ("GDPR"); (ii) Directive 2002/58/EC concerning the processing of personal data and the protection of privacy in the electronic communications sector; and (iii) applicable national implementations of (i) and (ii); or (iii) GDPR as it forms parts of the United Kingdom domestic law by virtue of Section 3 of the European Union (Withdrawal) Act 2018 ("UK GDPR"); and (iv) Swiss Federal Act on Data Protection of 25 September 2020 (Last amended on 7 July 2025) ("Swiss DPA"); in each case, as may be amended, superseded or replaced.  
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“Instructions” means the written, documented instructions issued by a Controller to a Processor, and directing the same to perform a specific or general action with regard to Personal Data (including, but not limited to, depersonalizing, blocking, deletion, making available).
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“Permitted Affiliates” means any of your affiliates that (i) are permitted to use Meedan Services pursuant to the Agreement, but have not signed their own separate agreement with us and are not a “User” as defined under the Agreement, (ii) qualify as a Controller of Personal Data Processed by us, and (iii) are subject to European Data Protection Laws.
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“Personal Data” means any information relating to an identified or identifiable individual where such information is contained within Company Data, including any data uploaded by the Company's end users, and is protected similarly as personal data, personal information or personally identifiable information under applicable Data Protection Laws.
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“Personal Data Breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Data transmitted, stored or otherwise Processed by us and/or our Sub-Processors in connection with the provision of Meedan Services. "Personal Data Breach" will not include unsuccessful attempts or activities that do not compromise the security of Personal Data, including unsuccessful log-in attempts, pings, port scans, denial of service attacks, and other network attacks on firewalls or networked systems.
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“Processing” means any operation or set of operations which is performed on Personal Data, encompassing the collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction or erasure of Personal Data. The terms “Process”, “Processes” and “Processed” will be construed accordingly.
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‍“Processor” means a natural or legal person, public authority, agency or other body which Processes Personal Data on behalf of the Controller.
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‍“Restricted Transfer” means a transfer of Personal Data to a third country or international organization for which the parties are required to implement the Standard Contractual Clauses, the UK Addendum, or another appropriate safeguard under Article 46 GDPR, Article 46 UK GDPR, or Article 16 FADP.
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“Standard Contractual Clauses” means the standard contractual clauses for Processors annexed to the European Commission’s Decision (EU) 2021/914 of 4 June 2021; as may be amended, superseded or replaced.
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“Sub-Processor” means any Processor engaged by us or our affiliates to assist in fulfilling our obligations with respect to the provision of the Meedan Services under the Agreement.  Sub-Processors may include third parties or our affiliates but will exclude any Meedan employee or consultant.

2. User Responsibilities

a. Compliance with Laws. Within the scope of the Agreement and in your use of the Services, you will be responsible for complying with all requirements that apply to your organization under applicable Data Protection Laws with respect to the Processing of Personal Data and the Instructions you issue to us.

In particular but without prejudice to the generality of the foregoing, you acknowledge and agree that you will be solely responsible for: (i) the accuracy, quality, and legality of Personal Data and the means by which you acquire Personal Data; (ii) complying with all necessary transparency and lawfulness requirements under applicable Data Protection Laws for the collection and use of the Personal Data, including obtaining any necessary consents and authorizations (particularly for use by you for research and/or marketing purposes); (iii) ensuring you have the right to transfer, or provide access to, the Personal Data to us for Processing in accordance with the terms of the Agreement (including this DPA); (iv) ensuring that your Instructions to us regarding the Processing of Personal Data comply with applicable laws, including Data Protection Laws; and (v) complying with all laws (including Data Protection Laws) applicable to any fact-checks or other content created, sent or managed through the Meedan Services, including those relating to obtaining consents (where required) to collect and share social media content, the content of shared and created content, and its publishing practices. You will inform us without undue delay if you are not able to comply with your responsibilities under this 'Compliance with Laws' section or applicable Data Protection Laws.

b. Controller Instructions. The parties agree that the Agreement (including this DPA), together with your use of the Meedan Services in accordance with the Agreement, constitutes your complete Instructions to us in relation to the Processing of Personal Data, however, you may provide additional instructions during the term that are consistent with the Agreement.

c. Security. You are responsible for independently determining whether the data security provided for in the Meedan Services adequately meets your obligations under applicable Data Protection Laws. You are also responsible for your secure use of Meedan Services, including protecting the security of Personal Data in transit to and from the Meedan Services (including to securely backup or encrypt any such Personal Data).

3. Meedan Obligations

a. Compliance with Instructions. We will only Process Personal Data for the limited and specific purposes described in this DPA or as otherwise agreed within the scope of your lawful Instructions, except where, and to the extent, otherwise required by applicable law. We are not responsible for compliance with any Data Protection Laws applicable to you or your industry that are not generally applicable to us.

b. Compliance with Laws. If we become aware that we cannot Process Personal Data in accordance with your Instructions due to a legal requirement under any applicable law, we will (i) promptly notify you of that legal requirement to the extent permitted by the applicable law; and (ii) where necessary, cease all Processing (other than merely storing and maintaining the security of the affected Personal Data) until such time as you issue new Instructions with which we are able to comply. If this provision is invoked, we will not be liable to you under the Agreement for any failure to perform the applicable Meedan Services until such time as you issue new lawful Instructions with regard to the Processing.

c. Security. We will implement and maintain appropriate technical and organizational measures to protect Personal Data from Personal Data Breaches, as described under Annex 2 to this DPA ("Security Measures"). Notwithstanding any provision to the contrary, we may modify or update the Security Measures at our discretion provided that such modification or update does not result in a material degradation in the protection offered by the Security Measures. 

d. Confidentiality. We will ensure that any personnel whom we authorize to Process Personal Data on our behalf is subject to appropriate confidentiality obligations (whether a contractual or statutory duty) with respect to that Personal Data.

e. Personal Data Breaches. We will notify you without undue delay after we become aware of any Personal Data Breach and will provide timely information relating to the Personal Data Breach as it becomes known or reasonably requested by you. At your request, we will promptly provide you with such reasonable assistance as necessary to enable you to notify relevant Personal Data Breaches to competent authorities and/or affected Data Subjects, if you are required to do so under Data Protection Laws.

f. Deletion or Return of Personal Data. We will delete or return all Personal Data (including copies thereof) processed pursuant to this DPA, on termination or expiration of your Meedan Services in accordance with the procedures set out in our Privacy Policy. This term shall apply except where we are required by applicable law to retain some or all of the Personal Data, or where we have archived Personal Data on backup systems, which data we will securely isolate and protect from any further Processing and delete in accordance with our deletion practices. You may request the deletion of your Meedan account and/or Personal Data after expiration or termination of your Meedan Services by sending a request to privacy@meedan.org.  

Where GDPR applies to the Personal Data, you can request the deletion up to 90 days after the termination or expiration of your Meedan Services by emailing privacy@meedan.org. Your Personal Data will be deleted within 30 days following a verified deletion request, subject to any statutory retention requirements and to Personal Data held in backup systems as described in the preceding paragraph. 

4. Data Subject Requests

The Meedan Services provide you with a number of controls that you can use to retrieve, correct, delete or restrict Personal Data, which you can use to assist it in connection with its obligations under Data Protection Laws, including your obligations relating to responding to requests from Data Subjects to exercise their rights under applicable Data Protection Laws ("Data Subject Requests"). 

To the extent that you are unable to independently address a Data Subject Request through the Meedan Services, then upon your written request, we will provide reasonable assistance to you to respond to any Data Subject Requests or requests from data protection authorities relating to the Processing of Personal Data under the Agreement. You shall reimburse us for the commercially reasonable costs arising from this assistance.

If a Data Subject Request or other communication regarding the Processing of Personal Data under the Agreement is made directly to us, we will promptly inform you and will advise the Data Subject to submit their request to you. You will be solely responsible for responding substantively to any such Data Subject Requests or communications involving Personal Data.

5. Sub-Processors

You agree that we may engage Sub-Processors to Process Personal Data on your behalf. We have currently appointed, as Sub-Processors, the Meedan affiliates and third parties identified in our current Sub-Processor lists, available at https://www.suwali.io/data-subprocessors/  (Suwali) and https://meedan.org/legal/check-data-subprocessors-list (Check). We will notify you if we add or replace any Sub-Processors listed on those sites at least 30 days prior to any such changes, if you opt-in to receive such email prior to any such changes by sending an email to privacy@meedan.org. We will give you the opportunity to object to the engagement of new Sub-Processors on reasonable grounds relating to the protection of Personal Data. If you do notify us of such an objection, the parties will discuss your concerns in good faith with a view to achieving a commercially reasonable resolution. If no such resolution can be reached, we will, at our sole discretion, either not appoint the new Sub-Processor, or permit you to suspend or terminate the affected Meedan Services in accordance with the termination provisions of the Agreement without liability to either party (but without prejudice to any fees incurred by you prior to suspension or termination).

Where we engage Sub-Processors, we will impose data protection terms on the Sub-Processors that provide at least the same level of protection for Personal Data as those in this DPA (including, where appropriate, the Standard Contractual Clauses), to the extent applicable to the nature of the services provided by such Sub-Processors. We will remain responsible for each Sub-Processor’s compliance with the obligations of this DPA and for any acts or omissions of such Sub-Processor that cause us to breach any of its obligations under this DPA.

6. Data Transfers

a. Global Processing. You acknowledge and agree that we may access and Process Personal Data on a global basis as necessary to provide the Meedan Services in accordance with the Agreement, and in particular that Personal Data may be transferred to and processed by Meedan Inc. in the United States and to other jurisdictions where Meedan affiliates and Sub-Processors have operations. Wherever Personal Data is transferred outside its country of origin, each party will ensure such transfers are made in compliance with the requirements of Data Protection Laws.

b. Safeguards Generally. Meedan shall not transfer European Data to any country or recipient not recognized as providing an adequate level of protection for Personal Data (within the meaning of applicable Data Protection Laws), unless it first takes all such measures as are necessary to ensure the transfer is in compliance with applicable Data Protection Laws. Such measures may include (without limitation) transferring such data to a recipient that is covered by a suitable framework or other legally adequate transfer mechanism recognized by the relevant authorities or courts as providing an adequate level of protection for Personal Data, to a recipient that has achieved binding corporate rules authorization in accordance with European Data Protection Laws, or to a recipient that has executed appropriate standard contractual clauses in each case as adopted or approved in accordance with applicable Data Protection Laws, where necessary, accompanied by additional security measures.

c. Standard Contractual Clauses Incorporated. You acknowledge that in connection with the performance of the Meedan Services, Meedan Inc. is a recipient of European Data in the United States. To facilitate the transfer of Personal Data to Meedan, the parties hereby agree to abide by and process European Data in compliance with the Standard Contractual Clauses, which are hereby incorporated into this DPA by reference. If and to the extent the Standard Contractual Clauses conflict with any provision of this DPA, the Standard Contractual Clauses will prevail.

d. Selection of Standard Contractual Clauses Modules, Options and Specifications.

  1. EU Transfers:
    1. Module Two Selected. The Standard Contractual Clauses are incorporated into this Addendum using module two (for Controller-to-Processor transfers).
    2. Clause 7 Applicability. Clause 7 (Docking Clause) shall apply.
    3. Clause 9 Specifications. The parties choose option 2 for subclause 9(a) and specify a time period of 30 calendar days for Processor to give Controller notice of intended additions and replacements to the list of Sub-Processors.
    4. Clause 17 Specifications. The parties specify the law of the Republic of Ireland as governing the Standard Contractual Clauses.
    5. Clause 18 Specifications. The parties specify the courts of the Republic of Ireland as the choice of forum for disputes arising from the Standard Contractual Clauses.
    6. Annexes. Annex I to the Standard Contractual Clauses is attached here as Annex 1; Annex II to the Standard Contractual Clauses is attached here as Annex 2; and Annex III to the Standard Contractual Clauses is available at https://www.suwali.io/data-subprocessors/ (Suwali) and https://meedan.org/legal/check-data-subprocessors-list (Check).
  2. UK Transfers. Where a Restricted Transfer is subject to the UK GDPR, the Standard Contractual Clauses apply as amended by the International Data Transfer Addendum to the EU Commission Standard Contractual Clauses (version B1.0, in force 21 March 2022) issued by the UK Information Commissioner (the "UK Addendum"). The following Part 2 Mandatory Clauses are incorporated into this DPA by reference: "Part 2: Mandatory Clauses of the Approved Addendum, being the template Addendum B.1.0 issued by the ICO and laid before Parliament in accordance with s119A of the Data Protection Act 2018 on 2 February 2022, as it is revised under Section 18 of those Mandatory Clauses." For the purposes of Part 1 of the UK Addendum: Table 1 is completed with the parties' details as set out in Annex 1; Table 2 is completed by reference to the 2021 EU Standard Contractual Clauses, Module Two, with the Clause 7 docking clause applying and the Clause 11 optional redress language not used, and the further selections as set out in this Section 6(d); Table 3 is completed with the information in Annexes 1 and 2 of this DPA and the subprocessor lists referenced in Section 5; and for Table 4, neither party may end the UK Addendum as set out in Section 19 of the UK Addendum.
  3. Swiss Transfers. Where a Restricted Transfer is subject to the Swiss Federal Act on Data Protection of 25 September 2020 ("FADP"), the Standard Contractual Clauses apply with the following adaptations: (i) references to the GDPR are to be understood as references to the FADP insofar as the transfer is subject to the FADP; (ii) the Swiss Federal Data Protection and Information Commissioner (FDPIC) is the competent supervisory authority with respect to transfers governed by the FADP, and the supervisory authority identified in Annex 1.C remains competent insofar as the transfer is also governed by the GDPR; (iii) with respect to transfers governed by the FADP, the law governing contractual claims under Clause 17 shall be Swiss law and the courts of Switzerland shall be competent under Clause 18(b); the law and courts selected in this Section 6(d) remain applicable insofar as the transfer is governed by the GDPR; and (iv) references to "Member State" in Clause 18(c) shall not be interpreted so as to exclude data subjects habitually resident in Switzerland from enforcing their rights in their place of habitual residence (Switzerland).

e. Meedan’s Representations Regarding the Effectiveness of the Standard Contractual Clauses.

  1. Processing in High-Risk Countries. Processor is established in the United States of America. Controller Personal Data is stored on servers located in Ireland. In the event of a Restricted Transfer, Controller Personal Data may be remotely accessed from the United States in limited circumstances (such as technical support and troubleshooting), subject to Processor's internal access controls.
  2. Applicability of FISA Section 702. Processor is very likely subject to Section 702 of the Foreign Intelligence Surveillance Act in the United States, a law that the European Court of Justice has found inadequately protects the rights and freedoms of Data Subjects.
  3. No FISA Section 702 Requests. Processor has never received any order or request for personal data under FISA 702 or under any similar national security or surveillance law of any other country. Processor is not subject to any court order or legal obligation that would prevent it from disclosing the existence or non-existence of such an order or request.
  4. Processor Policy on FISA Section 702 and Other Surveillance Requests. Processor has adopted a policy for responding to FISA Section 702 and Surveillance Requests. In such a case, Processor will suspend Processing, notify Controller, minimize disclosure of Controller Personal Data, and resist disclosure of Controller Personal Data, all as the law allows.
  5. No Other Disclosures; Obligation to Disclose. Processor is not aware of other relevant information in its possession that Controller would reasonably require to assess the effectiveness of the Standard Contractual Clauses as a transfer tool. Processor will promptly disclose any information that might bear on Controller’s assessment of the Standard Contractual Clauses in the event Processor gains knowledge of such information, as the law allows.

7. Additional Provisions for Data Processing 

a. Roles of the Parties. For the purposes of applicable law that uses the roles of Controller and Processor with respect to processing of Personal Data under this DPA, including when we process Personal Data in accordance with your Instructions, the parties acknowledge and agree that you are the Controller and we are the Processor. When processing California Personal Information in accordance with your Instructions, the parties acknowledge and agree that you are a Business and we are a Service Provider.

b. Instructions. If we believe that your Instruction infringes applicable data protection law, we will inform you without delay.

c. Data Protection Impact Assessments and Consultation with Supervisory Authorities. To the extent that the required information is reasonably available to us, and you do not otherwise have access to the required information, we will provide reasonable assistance to you with any data protection impact assessments, and prior consultations with supervisory authorities or other competent data privacy authorities to the extent required by European Data Protection Laws. 

d. Demonstration of Compliance. We will make all information reasonably necessary to demonstrate compliance with this DPA available to you and allow for and contribute to audits, including inspections conducted by your auditor in order to assess compliance with this DPA. You acknowledge and agree that you will exercise your audit rights under this DPA and Clause 8.9 of the Standard Contractual Clauses by instructing us to comply with the audit measures described in this 'Demonstration of Compliance' section. You acknowledge that the Meedan Services are hosted by our data center partners who maintain independently validated security programs (including SOC 2 and ISO 27001) and that our systems are regularly tested by independent third party penetration testing firms. Upon request, we will supply (on a confidential basis) a summary copy of its penetration testing report(s) to you so that you can verify our compliance with this DPA. Further, at your written request, we will provide written responses (on a confidential basis) to all reasonable requests for information made by you necessary to confirm our compliance with this DPA, provided that you will not exercise this right more than once per calendar year unless you have reasonable grounds to suspect non-compliance with the DPA.

8. General Provisions

a. Amendments. Notwithstanding anything else to the contrary in the Agreement and without prejudice to the ‘Compliance with Instructions’ or ‘Security’ sections of this DPA, we reserve the right to make any updates and changes to this DPA and the terms that apply in the ‘Amendment’ section of the Agreement will apply.

b. Severability. If any individual provisions of this DPA are determined to be invalid or unenforceable, the validity and enforceability of the other provisions of this DPA will not be affected.

c. Limitation of Liability. Each party and each of their affiliates' liability, taken in aggregate, arising out of or related to this DPA (and any other DPAs between the parties) and the Standard Contractual Clauses (where applicable), whether in contract, tort or under any other theory of liability, will be subject to the limitations and exclusions of liability set out in the 'Limitation of Liability' section of the Agreement and any reference in such section to the liability of a party means aggregate liability of that party and all of its affiliates under the Agreement (including this DPA). 

d. Governing Law. Unless required otherwise by Data Protection Laws, this DPA will be governed by and construed in accordance with the federal and state laws of the United States of America and the state of California, respectively without regard to conflict of law principles. The courts located in the City and County of San Francisco, California shall have exclusive jurisdiction over any dispute between the parties concerning this Agreement. The parties agree the venue of these courts is proper and submit to their jurisdiction, waiving any claim that such a proceeding has been brought in an inconvenient forum or that the venue of that proceeding is improper. 

9. Parties to this DPA

a. Permitted Affiliates. By signing the Agreement, you enter into this DPA (including, where applicable, the Standard Contractual Clauses) on behalf of yourself and in the name and on behalf of your Permitted Affiliates. For the purposes of this DPA only, and except where indicated otherwise, the terms “User”, “you” and “your” will include you and such Permitted Affiliates.

b. Authorization. The legal entity agreeing to this DPA as User represents that it is authorized to agree to and enter into this DPA for and on behalf of itself and, as applicable, each of its Permitted Affiliates.

c. Remedies. The parties agree that (i) solely the User entity that is the contracting party to the Agreement will exercise any right or seek any remedy any Permitted Affiliate may have under this DPA on behalf of its affiliates, and (ii) the User entity that is the contracting party to the Agreement will exercise any such rights under this DPA not separately for each Permitted Affiliate individually but in a combined manner for itself and all of its Permitted Affiliates together. The User entity that is the contracting entity is responsible for coordinating all Instructions, authorizations and communications with us under the DPA and will be entitled to make and receive any communications related to this DPA on behalf of its Permitted Affiliates.  

d. Other rights. The parties agree that you will, when reviewing our compliance with this DPA pursuant to the ‘Demonstration of Compliance’ section, take all reasonable measures to limit any impact on us and our affiliates by combining several audit requests carried out on behalf of the User entity that is the contracting party to the Agreement and all of its Permitted Affiliates in one single audit.

Annex 1 - Details of Processing

A. List of Parties

Data exporter:

Company details as set forth in the Agreement.

Activities relevant to the data transferred under these Clauses: Processing of Personal Data in connection with User's use of the Meedan Services under the Agreement

Role (controller/processor): Controller

Data importer:

Name: Meedan Inc.

Address: 365 Toni Stone Crossing, 3rd Floor, San Francisco, CA 94158, United States

Contact person’s name, position and contact details:  Dwight Knell, Director of Operations, sysops@meedan.org 

Activities relevant to the data transferred under these Clauses: Processing of Personal Data in connection with User's use of the Meedan Services under the Agreement

Role (controller/processor): Processor

B.  Description of Transfer

Categories of Data Subjects whose Personal Data is Transferred: You may submit Personal Data in the course of using the Meedan Services, the extent of which is determined and controlled by you in your sole discretion, and which may include, but is not limited to Personal Data relating to the following categories of Data Subjects: Your Contacts and other end users including your employees, contractors, collaborators, customers, prospects, suppliers, contributors, tipline users, and subcontractors. Data Subjects may also include individuals attempting to communicate with or transfer Personal Data to your end users.

Categories of Personal Data Transferred: You may submit Personal Data to the Meedan Services, the extent of which is determined and controlled by you in your sole discretion, and which may include but is not limited to the following categories of Personal Data: 

a. Contact Information (as defined in the Agreement).

b. End User Conversational Data
Meedan collects and retains conversation data from end user interactions, including user questions, interactions, and metadata. This category covers the full text of messages submitted by end users to the Suwali chatbot or a Check tipline via WhatsApp, Telegram, or any other messaging platform through which the service is made available, as well as any messages or tips submitted by users where that feature has been enabled by the partner organization.

c. Interaction Metadata
‍Metadata generated at each step of the conversation flow, including timestamps, session identifiers, message thread identifiers, and technical routing data associated with individual interactions.

d. Platform-Derived Identifiers
To the extent the messaging platforms through which Suwali operates (currently WhatsApp and Telegram) transmit user-level identifiers, such as phone numbers, user handles, or platform-assigned user IDs, in connection with end user messages. The nature and scope of this data is subject to the technical parameters of each messaging platform's API.

e. Partner Organization Personnel Data
‍To the extent individuals employed by or acting on behalf of the partner organization interact with the Suwali platform through the dashboard interface, their names, email addresses, login credentials, access logs, and usage activity constitute personal data transferred to Meedan as part of the service relationship.

f. Analytics-Derived Data
‍Meedan uses this data to generate analytics and insights, which are presented to the specific partner organization. To the extent those analytics are derived from or traceable to individual end users' interactions, for example, trend analyses based on identifiable conversation threads or user-level engagement patterns, they may constitute or involve personal data of the end users concerned.

Sensitive Data transferred: The parties do not intend for the Suwali service to process special categories of personal data. However, because the service operates through open-ended conversational interaction and the content of end user queries is entirely user-generated and unrestricted, the parties cannot technically prevent end users from voluntarily disclosing information that falls within a special category, including but not limited to information concerning health, political opinions, religious or philosophical beliefs, or other sensitive matters. The processing of such data, where it occurs, is therefore incidental, unstructured, and outside the control of either party. 

Frequency of the transfer: Continuous during the period of platform use.

Nature of the Processing
‍Personal Data will be Processed in accordance with the Agreement (including this DPA) and may be subject to the following Processing activities: 
1. Storage and other Processing necessary to provide, maintain and improve the Meedan Services provided to you; and/or
2. Disclosure in accordance with the Agreement (including this DPA) and/or as compelled by applicable laws.
3. Processing of end user queries, including transmission to and processing by third-party large language model providers engaged by Meedan as sub-processors, for the purpose of generating conversational responses. 
4. Retrieval of relevant content from databases maintained by Meedan on behalf of the partner organization using automated retrieval-augmented generation technology.
5. Analysis of interaction data and generation of aggregated and non-aggregated analytics, including trend analysis and audience insights, presented to the partner organization through the platform dashboard. 

Purpose of the transfer and further processing
‍We will process Personal Data as necessary to provide the Meedan Services pursuant to the Agreement, as further specified in the Order Form, and as further instructed by you in your use of the Meedan Services. For these purposes, the processing activities carried out by Meedan include the operation and delivery of the Suwali chatbot service and the transmission of end user queries to third-party large language model providers engaged by Meedan for the purpose of generating conversational responses; the retrieval of relevant content from databases maintained by Meedan on behalf of the partner organization; the generation of analytics and audience insights derived from interaction data and the presentation of those analytics to the partner organization through the platform dashboard; the maintenance and security monitoring of the technical infrastructure underlying the service; and the anonymization (or where not technically feasible, pseudonymization) of interaction data for the purpose of system improvement.

Period for which Personal Data will be retained
‍Subject to the 'Deletion or Return of Personal Data' section of this DPA, we will Process Personal Data for the duration of the Agreement, unless otherwise agreed in writing.

C. Competent Supervisory Authority

For the purposes of the Standard Contractual Clauses, the supervisory authority that shall act as competent supervisory authority is: (i) where data exporter is established in an EU Member State, the supervisory authority where Data Exporter is established; or  (ii) where data exporter is not established in an EU Member State but falls within the extra-territorial scope of the GDPR and has appointed a representative, the supervisory authority of the EU Member State in which data exporter’s representative is established; or (iii) where data exporter is not established in an EU Member State but falls within the extra-territorial scope of the GDPR without having to appoint a representative, the supervisory authority of the EU Member State in which the Data Subjects are predominantly located. 

For transfers governed by the FADP, the competent supervisory authority is the Swiss Federal Data Protection and Information Commissioner. For transfers also governed by the GDPR, the competent EU supervisory authority is determined as set out above.

Annex 2 - Security Measures

We currently observe the Security Measures described in this Annex 2. All capitalized terms not otherwise defined herein shall have the meanings as set forth in the Agreement.

a) Access Control

i)  Preventing Unauthorized Product Access: Outsourced processing: We host the Meedan Services with outsourced cloud infrastructure providers. Additionally, we maintain contractual relationships with vendors in order to provide the Meedan Services in accordance with our DPA. We rely on contractual agreements, privacy policies, and vendor compliance programs in order to protect data processed or stored by these vendors.

Physical and environmental security: We host our product infrastructure with multi-tenant, outsourced infrastructure providers. The physical and environmental security controls are audited for legal compliance.

Authentication: We implement a uniform password policy for our User products. Users who interact with the products via the user interface must authenticate before accessing non-public Personal Data.

Authorization: Personal Data is stored in multi-tenant storage systems accessible to users via only application user interfaces and application programming interfaces. Users are not allowed direct access to the underlying application infrastructure. The authorization model in each of our products is designed to ensure that only the appropriately assigned individuals can access relevant features, views, and customization options. Authorization to data sets is performed through validating the user’s permissions against the attributes associated with each data set.

Application Programming Interface (API) access: Public product APIs may be accessed using an API key or through OAuth authorization.

ii)  Preventing Unauthorized Product Use

We implement industry standard access controls and detection capabilities for the internal networks that support our products.

Access controls: Network access control mechanisms are designed to prevent network traffic using unauthorized protocols from reaching the product infrastructure. The technical measures implemented differ between infrastructure providers and include Virtual Private Cloud (VPC) implementations, security group assignment, and traditional firewall rules.

Intrusion detection and prevention: We implement a Web Application Firewall (WAF) solution to protect hosted User websites and other internet-accessible applications. The WAF is designed to identify and prevent attacks against publicly available network services.

Static code analysis: Security reviews of code stored in our source code repositories is performed, checking for coding best practices and identifiable software flaws.

Penetration testing: We maintain relationships with industry recognized penetration testing service providers for one annual penetration test. The intent of the penetration test is to identify and resolve foreseeable attack vectors and potential abuse scenarios.

iii)    Limitations of Privilege & Authorization Requirements

Product access: A subset of our employees have access to the products and to Personal Data via controlled interfaces. The intent of providing access to a subset of employees is to provide effective User support, to troubleshoot potential problems, to detect and respond to security incidents and implement data security. Access is enabled through “just in time” requests for access; all such requests are logged. Employees are granted access by role, and reviews of high risk privilege grants are initiated daily. Employee roles are reviewed at least once every six months.

Background checks: All Meedan employees undergo a third-party background check prior to being extended an employment offer, in accordance with and as permitted by the applicable laws. All Meedan employees are required to conduct themselves in a manner consistent with company guidelines, non-disclosure requirements, and ethical standards.

b) Transmission Control

In-transit: We make HTTPS encryption (also referred to as SSL or TLS) available on every one of its login interfaces and for free on every user site hosted on the Meedan products. Our HTTPS implementation uses industry standard algorithms and certificates.

At-rest: We store user passwords following policies that follow industry standard practices for security.  We have implemented technologies to ensure that stored data is encrypted at rest. 

c) Input Control

Detection: We designed our infrastructure to log extensive information about the system behavior, traffic received, system authentication, and other application requests. Internal systems aggregate log data and alert appropriate employees of malicious, unintended, or anomalous activities. Our personnel, including security, operations, and support personnel, are responsive to known incidents.

Response and tracking: We maintain a record of known security incidents that includes description, dates and times of relevant activities, and incident disposition. Suspected and confirmed security incidents are investigated by security, operations, or support personnel; and appropriate resolution steps are identified and documented. For any confirmed incidents, we will take appropriate steps to minimize product and User damage or unauthorized disclosure. Notification to you will be in accordance with the terms of the Agreement. 

d) Availability Control

Infrastructure availability: The infrastructure providers use commercially reasonable efforts to ensure high availability. The providers maintain a minimum of N+1 redundancy to power, network, and HVAC services.

Fault tolerance: Backup and replication strategies are designed to ensure redundancy and fail-over protections during a significant processing failure. Personal Data is backed up to multiple durable data stores and replicated across multiple availability zones.

Online replicas and backups: Where feasible, production databases are designed to replicate data between no less than 1 primary and 1 secondary database. All databases are backed up and maintained using at least industry standard methods.

Our products are designed to ensure redundancy and seamless failover. The server instances that support the products are also architected with a goal to prevent single points of failure. This design assists our operations in maintaining and updating the product applications and backend while limiting downtime.