Data Protection Addendum

This Data Protection Addendum ("Addendum") between CRSN Private Ltd. ("CRSN") and the Customer (as defined in the Agreement) forms part of the CRSN Private Ltd. Terms of Service set forth at https://www.crsn.in/terms-and-conditions or such other written or electronic agreement incorporating this Addendum, in each case governing Customer's access to and use of the Services (the "Agreement"). This addendum was last updated in August, 2026.

Customer enters into this Addendum on behalf of itself and any Affiliates authorized to use the Services under the Agreement and who have not entered into a separate contractual arrangement with CRSN. For the purposes of this Addendum only, and except where otherwise indicated, references to "Customer" shall include Customer and such Affiliates.

The Parties hereby agree that the terms and conditions set out below shall be added as an Addendum to the Agreement.

1. Definitions

In this Addendum, the following terms shall have the meanings set out below and cognate terms shall be construed accordingly:

The terms "Business", "Business Purpose", "commercial purpose", "Contractor", "Controller", "Data Subject", "Personal Data", "Personal Data Breach", "Process", "Processor", "Sell", "Service Provider", "Share", "Subprocessor", "Supervisory Authority", and "Third Party" have the same meanings as described in applicable Data Protection Laws and cognate terms shall be construed accordingly.

Capitalized terms not otherwise defined in this Addendum shall have the meanings ascribed to them in the Agreement.

2. Scope of Addendum

This Addendum applies to CRSN's Processing of Customer Personal Data under the Agreement to the extent such Processing is subject to Data Protection Laws. This Addendum is governed by the governing law of the Agreement unless otherwise required by Data Protection Laws.

3. Roles of the Parties

The Parties acknowledge and agree that with regard to the Processing of Customer Personal Data, and as more fully described in Annex 1 hereto, Customer acts as a Business or Controller, and CRSN acts as a Service Provider or Processor. This Addendum shall apply solely to the Processing of Customer Personal Data by CRSN acting as a Processor, Subprocessor, or Third Party (as specified in Annex 1).

The Parties expressly agree that Customer shall be solely responsible for ensuring timely communications to Customer's Affiliates or the relevant Controller(s) who receive the Services, insofar as such communications may be required or useful in light of applicable Data Protection Laws to enable Customer's Affiliates or the relevant Controller(s) to comply with such Laws.

Customer is solely responsible for complying with Security Incident notification laws applicable to Customer and fulfilling any obligations to give notices to government authorities, affected individuals or others relating to any Security Incidents.

4. Description and Purpose of Personal Data Processing

In Annex 1 to this Addendum, the Parties have mutually set out their understanding of the subject matter and details of the Processing of the Customer Personal Data to be Processed by CRSN pursuant to this Addendum. The Parties may make reasonable amendments to Annex 1 on mutual written agreement and as reasonably necessary to meet those requirements or to address the requirements of Data Protection Laws from time to time. Annex 1 does not create any obligation or rights for any Party.

The purpose of Processing under this Addendum is the provision of the Services pursuant to the Agreement and any Order Form(s).

5. Data Processing Terms

Customer Obligations

Customer shall comply with all applicable Data Protection Laws in connection with the performance of this Addendum and the Processing of Customer Personal Data. In connection with its access to and use of the Services, Customer shall Process Customer Personal Data within such Services and provide CRSN with instructions in accordance with applicable Data Protection Laws. As between the Parties, Customer shall be solely responsible for compliance with applicable Data Protection Laws regarding the collection of and transfer to CRSN of Customer Personal Data. Customer agrees not to provide CRSN with any data concerning a natural person's health, religion or any special categories of data as defined in Article 9 of the GDPR.

CRSN Processing Obligations

CRSN shall comply with all applicable Data Protection Laws in the Processing of Customer Personal Data and CRSN shall:

• Limited Purpose Processing: Process the Customer Personal Data for the purposes of the Agreement and for the specific purposes in each case as set out in Annex 1 to this Addendum and otherwise solely on the documented instructions of Customer, for the purposes of providing the Services and as otherwise necessary to perform its obligations under the Agreement.
• No Selling or Sharing: CRSN shall not Sell or Share Customer Personal Data, nor use, retain, disclose, or otherwise Process Customer Personal Data outside of its business relationship with Customer or for any other purpose (including CRSN's commercial purpose) except as required or permitted by law.
• Data Protection Compliance: Implement and maintain measures designed to ensure that CRSN personnel authorized to process the Customer Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality unless disclosure is required by law or professional regulations.
• Security Measures: Implement and maintain the technical and organizational measures set out in the Agreement, and implement and maintain any further commercially reasonable and appropriate administrative, technical, and organizational measures designed to ensure a level of security appropriate to the risk of the Processing of Customer Personal Data, including:
  • Pseudonymization and encryption of Customer Personal Data
  • Ensuring ongoing confidentiality, integrity, availability and resilience of processing systems
  • Restoring availability and access to Customer Personal Data in timely manner
  • Regular testing, assessing and evaluating effectiveness of technical and organizational measures
• Sub-processors: Customer hereby agrees that CRSN is generally authorized to engage and appoint Sub-processors, subject to CRSN's notification and data protection obligations. The Sub-processors currently engaged by CRSN are listed in Annex 2 to this Addendum.
• Legal Requests: To the extent legally permissible, promptly notify Customer in case of any legally binding requests for disclosure of Customer Personal Data by CRSN.
• Data Subject Requests: To the extent legally permissible, promptly notify Customer of any communication from a Data Subject regarding the Processing of Customer Personal Data.
• Security Incident Notification: Upon becoming aware of a Personal Data Breach involving Customer Personal Data, notify Customer without undue delay and take all measures necessary to remedy or mitigate the effects of such Security Incident.
• Assistance with Obligations: To the extent required by applicable Data Protection Laws, provide reasonable assistance to Customer with its obligations under Data Protection Laws.
• Data Deletion/Return: Cease Processing the Customer Personal Data upon the termination or expiry of the Agreement, and at option of Customer, either return or delete (including by ensuring such data is in non-readable format) all copies of the Customer Personal Data Processed by CRSN.
• Record Keeping: Maintain the necessary records in support of demonstrating compliance with its obligations for the processing of Customer Personal Data.
• Audit and Compliance: Make available to Customer all information reasonably necessary to demonstrate compliance with this Addendum and allow for and contribute to audits by Customer or independent third party auditors.

6. Warranties

The Parties warrant that they and any staff and/or subcontractors will comply with their respective obligations under Data Protection Laws for the term.

7. Restricted Transfers

The parties agree that when the transfer of Customer Personal Data from Customer and/or any of its Affiliates (as exporter) to CRSN (as importer) is a Restricted Transfer and EU Area Law applies, the transfer shall be subject to the appropriate Controller to Processor SCCs.

Location of AI Processing

CRSN shall process Personal Data using AI and machine learning technologies within the Microsoft Azure Central India region (India), in accordance with the terms of this Addendum and applicable Data Protection Laws, including the General Data Protection Regulation (GDPR). The purpose of such AI processing is limited to the services provided by the CRSN tool. CRSN shall ensure that any AI processing of Personal Data is conducted only to the extent necessary to achieve the specified purposes, and shall not change the region in which such processing occurs without notifying Customer in accordance with the Sub-processor notification provisions of Section 5.

India has not been the subject of an adequacy decision by the European Commission. Accordingly, where such AI processing involves a transfer of Customer Personal Data originating in the EU Area, that transfer is a Restricted Transfer and shall be effected pursuant to the Transfer Mechanisms set out in this Section 7, including the Controller to Processor SCCs, supported by a transfer impact assessment and by the Additional Safeguards described below.

Additional Safeguards

Customer should routinely review all international transfers of Personal Data on a case-by-case basis in order to monitor new risks because of the changes in local laws, data practices, etc., and implement additional safeguards (such as encryption or pseudonymization) to mitigate identified risks to ensure the Personal Data remains protected to the standard required under Data Protection Laws.

Transfer Mechanisms

Where a party is located outside the EEA or an adequate country and receives Personal Data, the following Transfer Mechanisms apply:

• Standard Contractual Clauses (SCCs) approved by the European Commission Decision of 4 June 2021
• International Data Transfer Agreement issued by the Information Commissioner's Office (ICO) under Section 119A of the Data Protection Act 2018
• International Data Transfer Addendum issued by the Information Commissioner's Office (ICO) under Section 119A of the Data Protection Act 2018

8. Precedence

The provisions of this Addendum are supplemental to the provisions of the Agreement. In the event of any inconsistency between the provisions of this Addendum and the provisions of the Agreement, they will take priority in this order: (a) any Standard Contractual Clauses or other measures to which the parties have agreed to (Cross-Border Transfer Mechanisms), (b) this Addendum, (c) the Agreement. In the event that any provision of this Addendum and/or the Agreement contradicts, directly or indirectly, the Controller to Processor SCCs, the Controller to Processor SCCs will control.

9. Indemnity

To the extent permissible by law, Customer shall (a) defend CRSN and its Affiliates (collectively, "Indemnified Parties") from and against any and all claims, demands, suits, or proceedings made or brought against any of the Indemnified Parties by any third party (each, a "Claim"), and (b) indemnify and hold harmless the Indemnified Parties from and against any and all losses, damages, liabilities, fines and administrative fines, penalties, settlements, and costs and expenses of any kind (including, without limitation, reasonable legal, investigatory and consultancy fees and expenses) incurred or suffered by any of the Indemnified Parties, in each case arising from any breach by Customer of this Addendum or of its obligations under applicable Data Protection Laws. CRSN may participate in the defense and/or settlement of a Claim under this Section with counsel of its choosing at its own expense.

10. Severability

The Parties agree that, if any section or sub-section of this Addendum is held by any court or competent authority to be unlawful or unenforceable, it shall not invalidate or render unenforceable any other section of this Addendum.

11. Miscellaneous

Principles and Standards

The Addendum considers the following and follows:

• Privacy by design and default
• Achieving security of Processing
• Notification of breaches involving Customer Personal Data to the relevant Supervisory Authority
• Notification of breaches involving Customer Personal Data to Customer
• Conducting Privacy Impact Assessments where appropriate and required by applicable Data Protection Law
• Assurance of CRSN's assistance if prior consultations with relevant Supervisory Authorities are needed and required by applicable Data Protection Laws

Compliance and Certifications

CRSN shall comply with all statutory and regulatory requirements, including:

• ISO/IEC 27001:2022 (certified)
• SOC 2 (independently audited)
• EU GDPR

Data Protection Officer

In the event a Data Subject wishes to exercise its data subject rights under applicable Data Protection Law, including, but not limited to, a data subject's right of access, correction and/or erasure of its Personal Data in CRSN's control, the Data Subjects can submit such request by contacting CRSN's Data Protection Officer (DPO) below. Also, for raising concerns and/or any complaints related to the Customer Personal Data that can be done by contacting the Data Protection Officer below:

Temporary Files

There are no Temporary files getting generated during processing.

Annex 1 to Data Protection Addendum

Description of Processing Activities for Customer Personal Data

List of Parties

Data Exporter

Data Importer

Processing Information

Categories of Data Subjects

Customer's authorized users of the Services

Categories of Personal Data Transferred

Processed automatically by the Services:

• Names
• Email IDs

Processed where and to the extent provided by Customer or its authorized users in connection with audit services provided by CRSN:

• Address
• Date of birth
• Past employment details

Sensitive Personal Data

None

Frequency of Transfer

Continuous

Nature of Processing

The nature of the processing is more fully described in the Agreement and accompanying order forms but will include the following basic processing activities: The provision of Services to Customer. In order to provide people data, CRSN receives identifying Customer Personal Data to permit CRSN to query, cleanse, standardize, enrich, (when required) send additional data to data providers, and to store the query information.

Purpose of Data Transfer

The purpose of the transfer is to facilitate the performance of the Services more fully described in the Agreement and accompanying order forms.

Technical and Organisational Security Measures

Security Management System

• Organization: CRSN designates qualified security personnel whose responsibilities include development, implementation, and ongoing maintenance of the Information Security Program.
• Policies: Management reviews and supports all security related policies to ensure the security, availability, integrity and confidentiality of Customer Personal Data. These policies are updated at least once annually.
• Assessments: CRSN engages a reputable independent third-party to perform risk assessments of all systems containing Customer Personal Data at least once annually.
• Risk Treatment: CRSN maintains a formal and effective risk treatment program that includes penetration testing, vulnerability management and patch management.
• Vendor Management: CRSN maintains an effective vendor management program.
• Incident Management: CRSN reviews security incidents regularly, including effective determination of root cause and corrective action.
• Standards: CRSN operates an information security management system that is certified to the ISO/IEC 27001:2022 standard and independently audited under SOC 2.

Personnel Security

CRSN personnel are required to conduct themselves in a manner consistent with the company's guidelines regarding confidentiality, business ethics, appropriate usage, and professional standards. CRSN conducts reasonably appropriate background checks on any employees who will have access to client data under this Agreement, including in relation to employment history and criminal records, to the extent legally permissible and in accordance with applicable local labor law.

Personnel are required to execute a confidentiality agreement in writing at the time of hire and to protect Customer Personal Data at all times. Personnel are provided with privacy and security training on how to implement and comply with the Information Security Program.

Access Controls

• Access Management: CRSN maintains a formal access management process for the request, review, approval and provisioning of all personnel with access to Customer Personal Data.
• Authentication: Administrators and end users must authenticate themselves via a Multi-Factor authentication system or via a single sign on system in order to use the Services.
• Privilege Management: CRSN designs its systems to only allow authorized persons to access data they are authorized to access based on principles of "least privileged" and "need to know".

Data Center and Network Security

• Infrastructure: CRSN uses Microsoft Azure as its cloud infrastructure provider, with workloads deployed across multiple Availability Zones.
• Backup & Disaster Recovery: CRSN conducts Backup Restoration Testing on regular basis and has designed disaster recovery programs that are regularly tested.
• Encryption: CRSN makes HTTPS encryption (SSL/TLS) available for data in transit and implements encryption technologies for data at rest.
• Vulnerability Management: CRSN performs regular vulnerability scans on all infrastructure components and remediates vulnerabilities on a risk basis.
• Data Storage: CRSN stores data in a multi-tenant environment on Microsoft Azure with logical isolation of customer data.

Annex 2 to Data Protection Addendum

List of Sub-processors

CRSN engages the following Sub-processors to Process Customer Personal Data in connection with the provision of the Services. CRSN shall notify Customer of any intended addition or replacement of a Sub-processor in accordance with Section 5 of this Addendum, and shall impose on each Sub-processor data protection obligations no less protective than those set out in this Addendum.