SN WHITE HOSTING – Data Processing Addendum (DPA)

Effective Date: February 21, 2026

1. Purpose of the Addendum

This Data Processing Addendum ("DPA") forms part of the Terms and Conditions of SN WHITE HOSTING™, operated by SN SOLUTIONS LLC (EIN: 32-0817400), and governs the processing of personal data we carry out on behalf of the Client, in accordance with Regulation (EU) 2016/679 (GDPR) and other applicable data protection laws.

2. Roles and Definitions

Controller: The Client, who determines the purposes and means of processing personal data.

Processor: SN WHITE HOSTING™, which processes personal data on behalf of the Client.

Sub-processor: Any third party engaged by SN WHITE HOSTING™ to carry out part of the processing.

3. Obligations of SN WHITE HOSTING™

We undertake to:

Process personal data only in accordance with documented instructions from the Client.

Ensure that persons authorized to process personal data are bound by confidentiality obligations.

Implement appropriate technical and organizational measures to ensure the security of personal data.

Assist the Client in complying with obligations regarding security, breach notifications, and impact assessments.

Delete or return all personal data upon termination of the services.

Cooperate with competent authorities and comply with judicial orders when legally required, notifying the Client where permitted.

4. Sub-processors

Clients authorize the use of sub-processors strictly necessary for service provision.

Any new or replacement sub-processors will be communicated at least 15 days in advance.

All sub-processors must comply with the same GDPR obligations outlined in this DPA.

5. International Transfers

Transfers outside the European Economic Area will be governed by appropriate legal mechanisms, such as Standard Contractual Clauses approved by the European Commission.

6. Data Security

Technical and organizational measures include encryption, access controls, backups, and system monitoring.

Measures are periodically reviewed for effectiveness.

7. Security Breach Notification

In case of a security breach affecting personal data, SN WHITE HOSTING™ will notify the Client without undue delay and provide relevant information to enable the Client to meet its legal obligations.

8. Data Subject Rights

SN WHITE HOSTING™ will assist the Client in fulfilling requests to exercise data subject rights (access, rectification, erasure, restriction, objection, portability) to the extent possible within our service scope.

9. Audits

The Client may, upon reasonable notice, audit compliance with this DPA, directly or via an independent auditor, provided such audits do not unreasonably interfere with our operations.

10. Amendments to the DPA

Amendments may be made to reflect legal, regulatory, or technical changes.

Clients will be notified at least 15 days in advance before amendments take effect.

11. Subprocessors and Security Compliance

All subprocessors or third parties engaged in data processing must comply strictly with GDPR.

SN WHITE HOSTING™ remains fully responsible for any breach caused by subprocessors.