Data Processing Addendum

This Data Processing Addendum (the “Addendum” or “DPA”) is entered into by and between WRITE RUBA's FULL LEGAL NAME HERE, with its principal place of business at [REGISTERED ADDRESS] (hereinafter referred to as “Ruba,” “Processor,” or “Service Provider”) and the subscribing customer entity utilizing Ruba’s infrastructure (hereinafter referred to as “Provider,” “Controller,” or “Business”).

This Addendum supplements and is expressly incorporated into the Ruba Master Services Terms or any other overarching commercial agreement governing the provision of Ruba's checkout, billing, and merchant of record solutions (collectively, the “Agreement”). This Addendum takes effect automatically upon the effective date of the Agreement (the “Effective Date”) and governs all processing of personal data conducted in connection with the Services.

PART I: CORE PROCESSING FRAMEWORK & RELATIONSHIP OF THE PARTIES

1. Agreement Structure & Scope of Processing

1.1. Contractual Incorporation. This Addendum establishes the legally binding standards, technical controls, and regulatory safeguards required whenever Ruba processes personal data on behalf of Provider while delivering its core infrastructure, subscription management, and payment enablement services. 1.2. Order of Precedence. If any conflict, ambiguity, or discrepancy arises between the provisions of this Addendum and the main text of the Agreement or any statement of work, the stricter data protection standards and terms of this Addendum shall strictly govern and supersede all conflicting terms with respect to data privacy and security. 1.3. Role Designation. The Parties acknowledge and formally agree that with respect to all Covered Data handled under the Agreement, Provider acts as the independent Data Controller (or “Business” under U.S. privacy laws) determining the purposes and means of processing, while Ruba acts exclusively as the Data Processor (or “Service Provider” under U.S. privacy laws) executing processing operations solely upon Provider's documented instructions.

2. Defined Terms & Regulatory Scope

In addition to terms defined elsewhere in the Agreement, the following capitalized terms shall carry the precise legal meanings set forth below throughout this Addendum: 2.1. “Covered Data” means any Personal Data or Personal Information submitted by Provider, uploaded through Provider’s integrations, or collected on Provider’s behalf by Ruba for the exclusive purpose of rendering the Services contracted under the Agreement. 2.2. “Data Protection Legislation” means all applicable local, national, and international laws, statutes, and regulatory frameworks governing data privacy, data security, and consumer protection, including but not limited to: a. The European Union General Data Protection Regulation (Regulation (EU) 2016/679) (“EU GDPR”) and the e-Privacy Directive (2002/58/EC); b. The United Kingdom General Data Protection Regulation and Data Protection Act 2018 (collectively, “UK GDPR”); c. The Swiss Federal Act on Data Protection (“FADP”); d. United States State Privacy Laws, including the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act (“CCPA/CPRA”), the Virginia Consumer Data Protection Act (“VCDPA”), the Colorado Privacy Act (“CPA”), the Connecticut Data Privacy Act (“CTDPA”), the Utah Consumer Privacy Act (“UCPA”), the Texas Data Privacy and Security Act (“TXDPSA”), the Florida Digital Bill of Rights (“FDBR”), the Montana Consumer Data Privacy Act (“MTCDPA”), the Oregon Consumer Privacy Act (“OCPA”), the Iowa Consumer Data Protection Act (“IADPA”), the Delaware Personal Data Privacy Act (“DEPDPA”), the Nebraska Data Privacy Act (“NEDPA”), the New Hampshire Privacy Act (“NHPA”), the New Jersey Data Privacy Act (“NJDPA”), the Tennessee Information Privacy Act (“TIPA”), the Minnesota Consumer Data Privacy Act (“MNCDPA”), the Maryland Online Data Privacy Act (“MDODPA”), the Indiana Consumer Data Protection Act (“INCDPA”), the Kentucky Consumer Data Protection Act (“KYCDPA”), and the Rhode Island Data Transparency and Privacy Protection Act (“RIDTPPA”). 2.3. “Data Subject” or “Consumer” means any identified or identifiable natural person whose Personal Data is processed within the Covered Data. 2.4. “Data Subject Request” means any formal inquiry, demand, or exercise of statutory rights submitted by a Data Subject under Data Protection Legislation, including rights to access, rectification, erasure, restriction, portability, or objection to targeted advertising and profiling. 2.5. “Personal Data” and “Personal Information” carry the definitions assigned by applicable Data Protection Legislation and shall be interpreted interchangeably to include any information relating to an identified or identifiable natural person processed by Ruba on Provider’s behalf. 2.6. “Processing” (and its cognates “Process” or “Processed”) means any operation or set of operations performed upon Covered Data, whether or not by automated means, including collection, recording, organization, structuring, storage, adaptation, retrieval, consultation, use, disclosure by transmission, dissemination, alignment, restriction, erasure, or destruction. 2.7. “Sub-processor” means any third-party business entity engaged directly or indirectly by Ruba to process Covered Data in support of delivering the Services.

3. Instructions & Purpose Limitations

3.1. Strict Adherence to Instructions. Ruba shall process Covered Data exclusively in accordance with Provider’s documented lawful instructions, as embodied in the Agreement, this Addendum, and any subsequent written directives issued by Provider. Ruba shall never retain, use, or process Covered Data for any independent or unauthorized purpose. 3.2. Mandatory Notification of Infringement. If Ruba determines that a processing instruction issued by Provider violates Data Protection Legislation, Ruba shall promptly inform Provider and may suspend execution of the infringing instruction until Provider modifies or confirms its legal validity. 3.3. Operational Scope. Ruba’s processing activities shall be strictly confined to what is reasonably necessary to operate, maintain, and secure the Ruba platform, process billing and checkout transactions, provide analytical reporting to Provider, and fulfill customer support obligations under the Agreement.

PART II: COMPREHENSIVE DATA PROTECTION & PRIVACY OBLIGATIONS

4. United States State Privacy Law Compliance (CCPA/CPRA & State Frameworks)

4.1. Statutory Prohibitions. To the extent that Covered Data encompasses Personal Information subject to the CCPA/CPRA or other U.S. State Privacy Laws, Ruba acts exclusively as a Service Provider and Processor. Ruba expressly covenants and warrants that it shall not: a. “Sell” or “Share” Covered Data, as those terms are strictly defined under California and applicable U.S. state statutes; b. Retain, use, disclose, or process Covered Data for any commercial purpose other than the specific business purposes authorized under the Agreement and this Addendum; c. Retain, use, or disclose Covered Data outside of the direct business relationship established between Ruba and Provider; or d. Combine or aggregate Covered Data received from or on behalf of Provider with personal data received from or collected on behalf of any other third party, except where explicitly permitted by statutory exemptions under the CCPA/CPRA to perform system optimization, fraud detection, or infrastructure security. 4.2. Authorized Business Purposes. In full alignment with statutory requirements, Ruba is expressly authorized to process Covered Data for the following operational business purposes: a. Fulfilling merchant transactions, processing recurring billing cycles, calculating tax remittances, and servicing end-user checkout sessions; b. Maintaining platform security, detecting fraudulent activities, preventing unauthorized system access, and protecting infrastructure integrity; c. Conducting debugging operations to identify and repair software glitches, network errors, or performance degradations; d. Executing short-term, transient processing operations where Covered Data is not disclosed to outside parties and is not utilized to construct persistent individual behavioral profiles; e. Performing internal research, technological development, and algorithmic optimization to enhance the reliability and safety of Ruba’s infrastructure. 4.3. Certification of Compliance. Ruba confirms that it fully understands the statutory restrictions and prohibitions contained within this Section 4 and covenants to comply with them unconditionally throughout the term of the Agreement.

5. Data Security & Technical Safeguards

5.1. Implementation of Controls. Taking into account the state of the art, implementation costs, and the nature, scope, context, and severity of risks to Data Subjects, Ruba shall design, deploy, and maintain robust technical and organizational security measures. These controls are structured to ensure a level of security appropriate to the risk, protecting Covered Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or physical access. 5.2. Adherence to Annex II. Without limiting the generality of Section 5.1, Ruba covenants to continually implement and maintain the specific administrative, physical, and technical controls detailed in Annex II (Technical and Organizational Measures) of this Addendum. 5.3. Personnel Confidentiality. Ruba shall ensure that all employees, contractors, and internal personnel who are granted access to Covered Data are bound by stringent contractual or professional obligations of confidentiality, and that access is restricted strictly on a least-privilege, need-to-know basis.

6. Security Incident Management & Breach Notification

6.1. Rapid Notification Protocol. In the event that Ruba discovers or discovers reasonable confirmation of a confirmed security incident, data breach, or unlawful intrusion leading to the accidental or unauthorized destruction, loss, alteration, disclosure of, or access to Covered Data (a “Security Incident”), Ruba shall notify Provider without undue delay and in no event later than seventy-two (72) hours after establishing the occurrence of the incident. 6.2. Content of Notification. Ruba’s breach notification shall be sent via electronic mail to Provider’s designated primary administrative contact and shall include, to the extent available at the time of notice: a. A description of the nature of the Security Incident, including the categories and approximate number of Data Subjects and records impacted; b. The name and contact details of Ruba’s data privacy team or data protection officer where further details can be obtained; c. An assessment of the likely consequences and potential risks arising from the Security Incident; and d. A summary of the corrective remediation measures and technical safeguards Ruba has taken or proposes to take to mitigate adverse impacts and secure the platform. 6.3. Remediation & Cooperation. Ruba shall take immediate, commercially reasonable steps to contain, investigate, and remediate any Security Incident. Ruba covenants to provide reasonable ongoing cooperation and assistance to Provider to facilitate Provider’s compliance with any mandatory regulatory notification or consumer disclosure laws.

7. Data Subject Rights & Consumer Assistance

7.1. Prompt Referral of Requests. If Ruba directly receives a Data Subject Request from an individual seeking to exercise statutory rights (such as access, erasure, restriction, or portability) concerning Covered Data, Ruba shall not independently respond to the request except to acknowledge receipt and instruct the individual to direct their request to Provider. Ruba shall promptly notify Provider of the incoming request. 7.2. Technical Assistance. Upon Provider’s written request, Ruba shall provide commercially reasonable technical assistance and platform functionality to enable Provider to fulfill its statutory obligations to respond to verified Data Subject Requests in accordance with Data Protection Legislation.

8. Regulatory Assessments & DPIA Support

8.1. Impact Assessment Cooperation. To the extent that Provider is required under EU GDPR, UK GDPR, or U.S. State Privacy Laws to conduct a Data Protection Impact Assessment (DPIA) or engage in prior consultation with supervisory authorities concerning processing activities executed by Ruba, Ruba shall provide reasonable technical documentation, security summaries, and assistance to support Provider’s compliance.

PART III: SUB-PROCESSING & INTERNATIONAL DATA TRANSFERS

9. Sub-Processor Engagement & Authorization

9.1. General Authorization. Provider grants Ruba general written authorization to engage third-party Sub-processors to assist in delivering the Services. A complete, updated roster of Ruba’s authorized Sub-processors is published and maintained at https://getruba.com/legal/sub-processors (the “Sub-processor List”). 9.2. Notice of Modifications. Ruba shall provide Provider with at least thirty (30) days' prior notice before adding or replacing any Sub-processor on the Sub-processor List. Notice shall be delivered via electronic mail or through platform notification channels. 9.3. Right to Object. Provider may submit a reasonable, documented objection to the appointment of a new Sub-processor within thirty (30) days of receiving notice, provided that such objection is based exclusively on legitimate, substantiated data protection and security risks. 9.4. Resolution of Objections. Upon receipt of a valid objection, the Parties shall collaborate in good faith to identify a commercially feasible operational workaround or alternative configuration. If no resolution can be reached within thirty (30) days, Provider shall have the right to terminate the affected Services immediately for cause, without penalty, upon written notice to Ruba. 9.5. Flow-Down Liability. Ruba covenants to enter into a formal written agreement with every Sub-processor that binds the Sub-processor to data protection and security obligations no less protective than those imposed upon Ruba under this Addendum. Ruba remains fully responsible and legally liable to Provider for all acts, omissions, and defaults of its Sub-processors to the same extent as if Ruba performed the processing directly.

10. Cross-Border Transfer Mechanisms

10.1. International Data Transfers. Where Ruba's performance of the Services necessitates the transfer of Covered Data originating in the European Economic Area (EEA), Switzerland, or the United Kingdom to a destination country outside those jurisdictions that has not received an formal adequacy decision from competent regulatory authorities, the Parties agree that such transfers shall be strictly governed by the approved transfer mechanisms set forth below. 10.2. EEA Transfers (EU SCCs). For transfers of Covered Data originating from the EEA or Switzerland, the Parties incorporate by reference and agree to be bound by the European Commission’s Standard Contractual Clauses for international data transfers adopted via Decision 2021/914/EU (the “EU SCCs”), set forth in Appendix A of this Addendum. The EU SCCs shall be deemed completed as follows: a. Module 2 (Controller to Processor) shall strictly apply; b. In Clause 7 (Optional Docking Clause), the optional language shall not apply; c. In Clause 9 (Use of Sub-processors), Option 2 (General Written Authorization) shall apply, with a mandatory advance notice period of thirty (30) days; d. In Clause 11 (Redress), the optional independent dispute resolution language shall not apply; e. In Clause 17 (Governing Law), Option 1 shall apply, and the EU SCCs shall be governed by the laws of Sweden; f. In Clause 18(b) (Choice of Forum and Jurisdiction), all legal disputes arising from the EU SCCs shall be resolved exclusively before the courts of Sweden; g. Annex I (Parties and Transfer Details) and Annex II (Technical and Organizational Measures) of the EU SCCs shall be deemed populated with the corresponding information set forth in Annex I and Annex II of this Addendum. 10.3. UK Transfers (UK IDTA). For transfers of Covered Data originating from the United Kingdom, the Parties incorporate by reference and agree to comply with the International Data Transfer Addendum to the EU Standard Contractual Clauses issued by the UK Information Commissioner’s Office under Section 119A(1) of the Data Protection Act 2018 (the “UK IDTA”), set forth in Appendix B of this Addendum. 10.4. Swiss Transfers. For transfers of Covered Data originating from Switzerland, the EU SCCs shall apply with the following statutory adaptations: references to the GDPR shall be construed as references to the Swiss Federal Act on Data Protection (FADP); references to the European Union or Member States shall include Switzerland; and the Swiss Federal Data Protection and Information Commissioner (FDPIC) shall act as the competent supervisory authority.

11. Government Access Demands & Transparency

11.1. Challenging Unlawful Demands. If Ruba receives a subpoena, court order, warrant, or binding demand from a governmental, regulatory, or law enforcement authority seeking compulsory disclosure of Covered Data, Ruba shall utilize commercially reasonable legal efforts to challenge the demand if there are reasonable grounds to believe the request is overly broad, unlawful, or deficient under applicable law. 11.2. Mandatory Notice to Provider. Unless strictly prohibited by statutory law or a binding judicial gag order, Ruba shall notify Provider immediately upon receiving a government access demand, providing full details of the request so that Provider may seek a protective order or file an independent legal intervention.

PART IV: LIFECYCLE MANAGEMENT, AUDITS & LEGAL GOVERNANCE

12. Data Deletion & Return Post-Termination

12.1. Post-Termination Erasure. Within thirty (30) days following the expiration, cancellation, or formal termination of the Agreement, Ruba shall, at Provider’s written election, securely erase or export and return all Covered Data stored within Ruba’s production infrastructure, backup databases, and temporary caches. 12.2. Statutory Retention Exceptions. Ruba shall not be obligated to destroy Covered Data to the extent that ongoing retention is strictly mandated by applicable accounting, fiscal, or Data Protection Legislation. In such events, Ruba covenants to isolate the retained Covered Data, suspend all active processing, and maintain enterprise-grade encryption and security controls until legal deletion becomes permissible. 12.3. Sub-processor Compliance. Ruba shall ensure that all engaged Sub-processors promptly execute identical data erasure or return procedures upon contract termination, subject to zero-day retention protocols where applicable.

13. Audit & Compliance Demonstration

13.1. Right to Audit. Upon receiving at least thirty (30) days' prior written notice from Provider, Ruba shall make available all necessary administrative documentation, compliance certificates, and third-party audit reports (such as SOC 2 Type II or ISO 27001 certifications) required to demonstrate Ruba's adherence to the data protection obligations of this Addendum. 13.2. On-Site Inspections. If Provider’s regulatory obligations mandate an independent on-site inspection or technical audit, such audit shall be conducted during normal business hours by an independent, certified third-party auditor approved by Ruba. The audit shall occur no more than once per calendar year (unless triggered by a confirmed Security Incident), and Provider shall bear all costs associated with the audit while ensuring zero disruption to Ruba’s shared cloud infrastructure.

14. Allocation of Liability & Indemnification

14.1. Cross-Indemnification. Each Party agrees to defend, indemnify, and hold harmless the other Party, including its directors, officers, employees, and authorized agents, against all third-party claims, regulatory fines, penalties, demands, and direct damages arising out of or resulting from the indemnifying Party’s negligent breach or willful violation of its obligations under this Addendum or applicable Data Protection Legislation. 14.2. Liability Caps. Any monetary liability arising out of or related to this Addendum, whether in contract, tort, or otherwise, shall be strictly subject to the overall limitation of liability and exclusion of consequential damages clauses stipulated in the Master Services Terms, except where Data Protection Legislation explicitly prohibits contractual limitation of liability toward Data Subjects.

15. Miscellaneous Provisions

15.1. Severability. If any clause or provision of this Addendum is held by a court of competent jurisdiction to be invalid, illegal, or unenforceable, such invalidity shall not affect the remaining terms, and the Parties shall substitute an enforceable provision that achieves the original legal and commercial intent as closely as possible. 15.2. Counterparts & Execution. This Addendum may be executed in counterparts or via electronic signature, each of which shall be deemed an original binding instrument. 15.3. Governing Law. This Addendum shall be governed by and construed in accordance with the laws of the jurisdiction specified in the Agreement, except where the EU SCCs or UK IDTA require the application of specific European or UK legal frameworks.

APPENDIX A: EUROPEAN UNION STANDARD CONTRACTUAL CLAUSES

The European Commission’s Approved Standard Contractual Clauses (Decision 2021/914/EU) — Module 2: Transfer from Controller to Processor.

SECTION I

Clause 1: Purpose and scope (a) 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 data to a third country. (b) The Parties: (i) 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 (ii) 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’). (c) These Clauses apply with respect to the transfer of personal data as specified in Annex I.B. (d) 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 (a) 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. (b) 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 (a) Data subjects may invoke and enforce these Clauses, as third-party beneficiaries, against the data exporter and/or data importer, with the following exceptions: (i) Clause 1, Clause 2, Clause 3, Clause 6, Clause 7; (ii) Clause 8.1(b), 8.9(a), (c), (d) and (e); (iii) Clause 9(a), (c), (d) and (e); (iv) Clause 12(a), (d) and (f); (v) Clause 13; (vi) Clause 15.1(c), (d) and (e); (vii) Clause 16(e); (viii) Clause 18(a) and (b). (b) Paragraph (a) is without prejudice to rights of data subjects under Regulation (EU) 2016/679.

Clause 4: Interpretation (a) Where these Clauses use terms that are defined in Regulation (EU) 2016/679, those terms shall have the same meaning as in that Regulation. (b) These Clauses shall be read and interpreted in the light of the provisions of Regulation (EU) 2016/679. (c) 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 [Intentionally omitted pursuant to Section 10.2(b) of this Addendum]

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.

8.1 Instructions (a) 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. (b) 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 (a) 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. (b) 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. (c) 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. (d) 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: (i) 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; (ii) 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; (iii) 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 (iv) 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 (a) The data importer shall promptly and adequately deal with enquiries from the data exporter that relate to the processing under these Clauses. (b) 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. (c) 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. (d) 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. (e) 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 (a) OPTION 2: 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 thirty (30) 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. The list of sub-processors already authorised by the data exporter is published at https://getruba.com/legal/sub-processors. (b) 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. (c) 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. (d) 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. (e) 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 (a) 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. (b) 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. (c) In fulfilling its obligations under paragraphs (a) and (b), the data importer shall comply with the instructions from the data exporter.

Clause 11: Redress (a) 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. (b) 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. (c) 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: (i) 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; (ii) refer the dispute to the competent courts within the meaning of Clause 18. (d) 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. (e) The data importer shall abide by a decision that is binding under the applicable EU or Member State law. (f) 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 (a) 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. (b) 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. (c) 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. (d) 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. (e) 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. (f) 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. (g) The data importer may not invoke the conduct of a sub-processor to avoid its own liability.

Clause 13: Supervision (a) Where the data exporter is established in an EU Member State, 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. Where the data exporter 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) without however having to appoint a representative pursuant to Article 27(2), the supervisory authority of one of the Member States in which the data subjects whose personal data is transferred under these Clauses in relation to the offering of goods or services to them, or whose behaviour is monitored, are located, as indicated in Annex I.C, shall act as competent supervisory authority. (b) 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 (a) 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. (b) The Parties declare that in providing the warranty in paragraph (a), they have taken due account in particular of the following elements: (i) 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; (ii) 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; (iii) 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. (c) 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. (d) The Parties agree to document the assessment under paragraph (b) and make it available to the competent supervisory authority on request. (e) 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 Clause 14(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). (f) 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.

Clause 15: Obligations of the data importer in case of access by public authorities 15.1 Notification (a) 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: (i) 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 (ii) 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. (b) 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. (c) 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.). (d) 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. (e) 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 (a) 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). (b) 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. (c) 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 (a) The data importer shall promptly inform the data exporter if it is unable to comply with these Clauses, for whatever reason. (b) 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. (c) The data exporter shall be entitled to terminate the contract, insofar as it concerns the processing of personal data under these Clauses, where: (i) 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; (ii) the data importer is in substantial or persistent breach of these Clauses; or (iii) 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 of termination only with respect to the relevant Party, unless the Parties have agreed otherwise. (d) 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.

Clause 17: Governing law Option 1: 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 Sweden.

Clause 18: Choice of forum and jurisdiction (a) Any dispute arising from these Clauses shall be resolved by the courts of an EU Member State. (b) The Parties agree that those shall be the courts of Sweden. (c) 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. (d) The Parties agree to submit themselves to the jurisdiction of such courts.

ANNEX I TO THE EU STANDARD CONTRACTUAL CLAUSES

A. LIST OF PARTIES

Data Exporter(s):

1. Name: The subscribing customer entity (“Provider”) executing the Master Services Terms or commercial agreement with Ruba. Address: As specified in the Provider’s account registration or applicable commercial order form. Contact Person’s Name, Position, and Contact Details: The designated primary administrative or data protection contact specified in Provider’s account portal. Activities Relevant to the Data Transferred: Utilizing Ruba’s infrastructure for checkout, merchant of record billing, subscription management, and transaction processing. Signature and Date: Deemed executed automatically upon Provider entering into the Agreement and utilizing the Services. Role: Data Controller (or Business).

Data Importer(s):

1. Name: WRITE RUBA's FULL LEGAL NAME HERE Address: [REGISTERED ADDRESS] Contact Person’s Name, Position, and Contact Details: Privacy & Legal Compliance Team — privacy@getruba.com / legal@getruba.com Activities Relevant to the Data Transferred: Providing cloud infrastructure, payment orchestration, tax remittance, and merchant of record platform services on behalf of Provider. Signature and Date: Deemed executed automatically upon the Effective Date of the Agreement. Role: Data Processor (or Service Provider).

B. DESCRIPTION OF TRANSFER

1. Categories of Data Subjects: The personal data transferred concerns end-user customers, buyers, subscribers, employees, and authorized administrative users of the Provider utilizing or interacting with Ruba's checkout and billing interfaces.

2. Categories of Personal Data Transferred: The transfer encompasses transaction and billing data, including end-user names, email addresses, billing and shipping addresses, IP addresses, device identifiers, order details, subscription tiers, tax identification numbers, and partial payment token metadata (note: full credit card primary account numbers are ingested directly by PCI-DSS Level 1 certified payment processors and are not stored in raw text on Ruba server databases).

3. Sensitive Data Transferred: Ruba’s infrastructure is not intended for the storage or processing of special categories of sensitive data (e.g., biometric data, health records, religious beliefs, or racial origin). Sensitive data is processed only if Provider or its end-users explicitly and voluntarily input such information into customized text fields or metadata tags within the Services.

4. Frequency of the Transfer: Transfers occur on a continuous, real-time basis as transactions, checkouts, and API requests are executed across the Ruba platform.

5. Nature of the Processing: Automated collection, recording, structuring, storage, retrieval, hosting, tax calculation, transaction routing, and customer support analytics strictly necessary to deliver the platform features defined in the Agreement.

6. Purpose(s) of the Data Transfer and Further Processing: Enabling Ruba to perform its contractual obligations under the Agreement, including processing end-user payments, managing recurring subscription billing cycles, remitting global sales taxes, and maintaining platform security and uptime.

7. Retention Period: Personal data shall be retained for the active duration of the Agreement and for up to three (3) years thereafter, or as required by statutory accounting, tax, and anti-money laundering (AML) laws. Upon expiration of legal retention requirements, data is permanently purged or anonymized.

C. COMPETENT SUPERVISORY AUTHORITY

In accordance with Clause 13 of the EU SCCs, the competent supervisory authority governing this transfer shall be the Swedish Authority for Privacy Protection (Integritetsskyddsmyndigheten - IMY).

ANNEX II: TECHNICAL AND ORGANISATIONAL MEASURES (TOMs)

Ruba implements, maintains, and continuously enforces the following comprehensive enterprise security controls to safeguard Covered Data against unauthorized access, loss, or degradation:

1. Information Security Governance & Policies: Ruba maintains a written information security program aligned with industry best practices (such as SOC 2 Type II and ISO 27001 standards). Security policies are reviewed annually and enforced across all operational teams.
2. Access Control & Least Privilege: Access to production infrastructure and databases containing Covered Data is restricted strictly to authorized engineering personnel via role-based access controls (RBAC) and principle of least privilege. Mandatory multi-factor authentication (MFA) and cryptographic SSH keys are enforced for all administrative sessions.
3. Data Encryption (In Transit & At Rest): All network traffic transporting Covered Data across public or external networks is encrypted using modern cryptographic protocols (TLS 1.2 or higher with perfect forward secrecy). All databases, volumes, and object backups storing Covered Data at rest are encrypted using AES-256 encryption with cloud-managed key vaults.
4. Vulnerability Management & Container Security: Ruba conducts automated vulnerability scanning across all codebases, dependencies, and container images prior to production deployment. Continuous CI/CD pipeline scanning prevents the introduction of malware, unpatched libraries, or insecure configurations.
5. Physical & Environmental Security: Ruba hosts its production infrastructure on tier-1, hyperscale cloud providers (e.g., AWS, GCP) featuring 24/7 biometric access controls, armed perimeter security, redundant power grids, and automated fire suppression systems.
6. Network Security & Intrusion Detection: Production environments are segregated within Virtual Private Clouds (VPCs) with strict firewall rules, web application firewalls (WAF), and automated DDoS mitigation protocols. System logs are continuously ingested and monitored for anomalous activities.
7. Business Continuity & Disaster Recovery: Ruba performs automated, encrypted daily database backups replicated across geographically separate availability zones. Disaster recovery plans and data restoration protocols are tested periodically to ensure rapid recovery in the event of an infrastructure disruption.
8. Government Access Defense Program: Ruba enforces a strict administrative policy requiring formal legal review of all government or law enforcement subpoenas seeking data access. Ruba will legally challenge overly broad or warrantless requests and maintains logging procedures to document all inquiries.

APPENDIX B: UK INTERNATIONAL DATA TRANSFER ADDENDUM (UK IDTA)

International Data Transfer Addendum to the EU Commission Standard Contractual Clauses (Version B1.0, issued by the UK Information Commissioner's Office under S119A(1) Data Protection Act 2018).

Table 1: Parties

• The Parties: Exporter (Provider / Controller) and Importer (Ruba / Processor).
• Parties' Details: Full legal names, addresses, trading names, and official registration numbers are as specified verbatim in Annex I.A of this Addendum.
• Key Contacts: Primary administrative contacts and email addresses are as specified in Annex I.A of this Addendum.
• Signature: Deemed executed automatically and concurrently with the execution of the Agreement and this Addendum.

Table 2: Selected SCCs, Modules and Selected Clauses

• Approved EU SCCs: The European Commission Approved Standard Contractual Clauses (Decision 2021/914/EU), Module 2 (Controller to Processor), as incorporated and adapted pursuant to Section 10.2 and Appendix A of this Addendum, including all completed Annexes and selections made therein.

Table 3: Appendix Information

• Annex 1A (List of Parties): As set forth in Annex I.A of this Addendum.
• Annex 1B (Description of Transfer): As set forth in Annex I.B of this Addendum.
• Annex 1C (Competent Supervisory Authority): As set forth in Annex I.C of this Addendum (adapted for the UK Information Commissioner's Office where applicable).
• Annex 2 (Technical and Organisational Measures): As set forth in Annex II of this Addendum.

Table 4: Ending this Addendum when the Approved Addendum Changes

• Termination Rights: Either Party (Exporter or Importer) may terminate this UK IDTA if the UK Information Commissioner's Office issues a revised or replacement standard addendum under Section 119A of the Data Protection Act 2018, in accordance with Section 19 of the mandatory UK IDTA terms.