Sitecore Data Processing Addendum

ANNEX D: Mechanisms for Personal Data Transfers

The parties have agreed on the following Data Transfer Mechanisms in order to adduce adequate safeguards with respect to the protection of privacy and fundamental rights and freedoms of individuals for the transfer by the data exporter to the data importer of the personal data specified in Appendix 1.

Standard Contractual Clauses. For the purposes of Article46 (2) of Regulation 2016/679 for the transfer of personal data to processors established in third countries which do not ensure an adequate level of data protection, the Standard Contractual Clauses are the adequate transfer mechanism. For purposes of the Standard Contractual Clauses, the Parties agree:

(a) Clause 7 (Docking Clause)shall not apply;

(b) For Clause 9 (General Authorisation), Option 2 shall apply;

(c) For Clause 13 (Supervision), the Supervisory Authority with responsibility for ensuring compliance by the data exporter with the GDPR with regard to Restricted Transfers, namely, the lead Supervisory Authority of the data exporter, shall act as the competent Supervisory Authority; and

(d) For Clause 17 (Governing Law), Option 1 shall apply.

Restricted Transfers Under UK GDPR. For transfers of personal data in compliance with section 119(A)and article 46 of the Data Protection Act 2018, the parties agree that the Standard Contractual Clauses supplemented by the International Data Transfer Add endumare the appropriate transfer mechanism.

Swiss Addendum to the EU Commission Standard Contractual Clauses. For transfers of personal data in compliance with the Federal Act on Data Protection 1992("FADP"), the parties agree that the Standard Contractual Clauses supplemented by the Swiss Addendum to the EU Commission Standard Contractual Clauses are the appropriate transfer mechanism.

The Standard Contractual Clauses and applicable Addendums to the Standard Contractual Clauses are linked below:

Click here for the Standard Contractual Clauses

Click here for the International Data Transfer Addendum

Click here for the Swiss Addendum to the EU Commission Standard Contractual Clauses