This Data Processing Agreement (“DPA”) forms an integral part of, and is subject to, the agreement between Addressable Ltd., a company with offices located at Hayarkon 323 St. Tel -Aviv, Israel (“Addressable”) and its relevant customer (the “Customer”) with respect to Addressable’s services and offerings, that references this DPA or to which this DPA is attached (the “Principal Agreement”), and any related Order Forms or similar purchase instruments governing the use of Adressable’s services (the DPA together with the Principal Agreement and any such Order Forms, are collectively referred to as the “Agreement"). Addressable and Customer are hereinafter jointly referred to as “Parties” and individually as “Party.” Capitalized terms not otherwise defined herein shall have the meaning given to them in the Principal Agreement.
By using the Addressable Services or otherwise entering into the Principal Agreement, Customer accepts this DPA, and Customer represents and warrants that it has full authority to bind the Customer to this DPA.
1. Definitions
“Affiliate” means any entity that directly or indirectly controls, is controlled by, or is under common control with the subject entity. “Control” for purposes of this definition means direct or indirect ownership or control of more than 50% of the voting interests of the subject entity.
“Applicable Laws” means (a) European Union or Member State laws addressing any Customer Personal Data in respect of which Customer is subject to EU Data Protection Laws; and (b) any other applicable law addressing any Customer Personal Data.
"Customer Data" means all data, works and materials: (i) inputted by the Customer to the Platform; (ii) collected by Addressable’s access to Customer’s social network advertising account, that were already held by Customer on the date the Principal Agreement entered into effect.
“Customer Personal Data” means any Personal Data Processed by Addressable as part of its processing of Customer Data on behalf of Customer pursuant to or in connection with the Principal Agreement, as Specified in Annex 1. Customer Personal Data shall not include any Service Data.
“Data Protection Laws” means (a) EU Data Protection Laws; (b) the UK GDPR; (c) the Swiss FADP, and (d) to the extent applicable, the data protection or privacy laws of any other applicable country as agreed in writing between the Parties, including the United States and Israel.
“EU Data Protection Laws” means EU Directive 95/46/EC, as transposed into domestic legislation of each Member State and as amended, replaced or superseded from time to time, including by the GDPR and laws implementing or supplementing the GDPR.
"FADP” means the Swiss Federal Act on Data Protection dated 19 June 1992 and any subsequent amendments, replacements, or supplements including any guidelines and clarifying materials published by the Swiss Federal Data Protection and Information Commissioner (FDPIC).
“GDPR” means EU General Data Protection Regulation 2016/679 and any subsequent amendments, replacements or supplements.
“Restricted Transfer” means (i) a transfer of Customer Personal Data from Customer to Addressable; or (ii) an onward transfer of Customer Personal Data from Addressable to a Sub Processor, or between two establishments of Addressable, in each case, where such transfer would be prohibited by Data Protection Laws (or by the terms of data transfer agreements put in place to address the data transfer restrictions of Data Protection Laws) in the absence of a legal transfer mechanism to be established under this DPA, including without limitation the applicable Standard Contractual Clauses.
“Service Data” means any information, inferred, generated, or otherwise obtained by Addressable in the scope of the provision of the Services and/or the Platform to Customer, excluding Customer Data, and including without limitation, any insights derived or inferred by Addressable in the scope of the provision of the Services and/or the Platform to the Customer.
“Sub Processor” means any third party (including any Addressable Affiliate, but excluding an employee of Addressable or any of its sub-contractors) appointed by or on behalf of Addressable or any Addressable Affiliate to Process Customer Personal Data on behalf of the Customer in connection with the Principal Agreement.
“UK GDPR” means the United Kingdom’s Data Protection Act 2018 and the GDPR as adapted into law of the United Kingdom by virtue of section 3 of the United Kingdom’s European Union (Withdrawal) Act 2018.
The terms, “Data Subject,” “Member State,” “Personal Data,” “Personal Data Breach,” “Special Categories of Data,” “Process/Processing,” “Controller,” “Processor,” and “SupervisoryAuthority,” shall have the same meanings given to them in the GDPR (or another applicable Data Protection Law).
2. Processing of Customer Personal Data
The provisions of this DPA shall only apply with respect to Customer Personal Data processed by Addressable on behalf of Customer as a result of Customer’s use of Addressable’s Services, as described in Annex 1 (Details of Processing of Customer Personal Data) attached hereto. (Notwithstanding the above, Section 3 hereto, applies to Service Data not processed by Addressable) on behalf of Customer. In connection with each Party’s rights and obligations under this Agreement, as between the Parties, Addressable shall Process Customer Personal Data solely as a data Processor acting on behalf of Customer, and Customer shall be deemed the Controller of such Customer Personal Data.
Addressable shall not Process Customer Personal Data other than according to the Customer’s documented reasonable and customary instructions as specified in the Principal Agreement or this DPA, which were specifically and explicitly agreed to by Addressable, unless such Processing is required by Applicable Laws. Addressable shall inform the Customer of such legal requirement before processing unless the law prohibits such action on public interest grounds.
Customer instructs Addressable (and authorizes Addressable to instruct each Sub Processor) to (i) Process Customer Personal Data only to the extent required for the provision of Addressable’s Services under the Agreement.
Furthermore, Customer warrants and represents that it is and will remain duly and effectively authorized to give the instruction set out in Section 2.1 and any additional instructions as provided pursuant to the Agreement and/or in connection with the performance thereof, on behalf of itself and each relevant Customer Affiliate, at all relevant times and at least for as long as the Agreement is in effect and for any additional period during which Addressable is lawfully processing the Customer Personal Data. In addition, Customer warrants and represents that it has obtained all permissions, consents, authorizations and approvals, including by making all notices, required for it to allow Addressable to access and process Customer Personal Data as permitted hereunder.
Customer sets forth the details of the Processing of Customer Personal Data, as required by Article 28(3) of the GDPR in Annex 1 (Details of Processing of Customer Personal Data), attached hereto.
Customer hereby represents and warrants that Customer has provided sufficient notices and obtained necessary or advisable consents required from any third-party and otherwise has the lawful basis upon which to share the Customer Personal Data, with Addressable and its Affiliates, and to make any and all uses as otherwise contemplated under this Agreement.
3. Independent Data Controller
It is agreed and clarified that each party shall act as an independent data Controller with respect to Service Data collected, processed or otherwise obtained by such Party in connection with the Principal Agreement and performance thereunder. Moreover, enriched data that Addressable provides to the Customer: (a) originates from Addressable’s identity graph database, for which Addressable is the controller; (b) is not Customer Personal Data; and (c) forms a controller-controller transfer.
In such respects, each party shall be individually and separately responsible for complying with the obligations that apply to it as an independent data Controller under the GDPR and Applicable Law and except for Section 1, this Section 3, and Section 13 and 14, all other provisions of this DPA shall not apply to the Parties with respect to their role and capacity as independent controllers of Service Data.
Each party undertakes to: provide notice or transparency to Data Subjects or to obtain an individual’s consent if and as required under Applicable Law, with regards to the processing of Services Data it. Specifically Customer shall be responsible to notify the Data Subjects and obtain their consent, that Service Data is processed and controlled by Addressable according to Addressable’s Privacy Policy available at: [https://www.addressable.io/privacy-policy] (“Addressable’s Privacy Policy”)
Implement and maintain appropriate technical and organizational measures to ensure a level of security appropriate to the risk associated with the Processing activities, including measures to protect against unauthorized or unlawful Processing and against accidental loss, destruction, or damage.
Determine the legal bases for the Processing of Service Data, ensuring that all Processing activities are conducted lawfully, fairly, and transparently without adversely affecting the rights of the Data Subjects.
Respond to Data Subject requests exercising their rights under Applicable Laws (such as access, rectification, erasure, data portability, and the right to object) in a timely and efficient manner.
Maintain a record of Processing activities under its responsibility, detailing the purposes of Processing, categories of Data Subjects and Personal Data, and where applicable, the transfers of Personal Data to third countries and the documentation of suitable safeguards.
Indemnify and hold harmless the other Party against all third party claims, actions and related losses, damages, and expenses finally awarded against the other Party, arising out of any non-compliance by the indemnifying Party with its obligations as an independent Controller under this DPA and Applicable Laws.
4. Customer Obligations
Customer shall comply with all applicable laws in connection with the performance of this DPA. As between the Parties, Customer shall be solely responsible for compliance with applicable laws (including Data Protection Laws) regarding its collection and transfer of Customer Personal Data to Addressable. Customer agrees not to provide Addressable with any special categories of data, as defined in Article 9 of the GDPR, other than as provided in Annex 1 (Details of Processing of Customer Personal Data).
5. Addressable Personnel
Addressable shall take reasonable steps to ensure that access to the Customer Personal Data is limited on a need to know/access basis, and that all Addressable personnel receiving such access are subject to confidentiality undertakings or professional or statutory obligations of confidentiality in connection with their access/use of Customer Personal Data.
6. Security
In relation to the Customer Personal Data, Addressable shall implement appropriate technical and organizational measures as identified under Annex 2 (Technical and Organizational Measures) including to the extent appropriate and applicable the measures referred to in Article 32(1) of the GDPR, to establish an appropriate level of security for the Customer Personal Data. Such security has to be sustained throughout the entire duration of this DPA and must aim to (i) ensure the ongoing confidentiality and security of Processing systems and services in connection with the Processing of the Customer Personal Data; and (ii) restore the availability and access to Customer Personal Data in a timely manner in the event of a physical or technical incident. In assessing the appropriate level of security, Addressable shall consider the risks presented by Processing, paying particular attention to risks arising from a Personal Data Breach.
7. Sub Processing
Customer authorizes Addressable and each Addressable Affiliate to appoint (and permit each Sub Processor appointed in accordance with this Section 7 to appoint) Sub Processors in accordance with this Section 7 and any restrictions in the Agreement.
Addressable and each Addressable Affiliate may continue to use those Sub Processors already engaged by Addressable or any Addressable Affiliate as of the date of this DPA as identified in the Sub processors List or as otherwise notified by Addressable concurrently with entering into the Principal Agreement, including for the purpose of cloud hosting services by reputable Sub Processors, as well as any Sub Processors whom Customer requested Addressable to use.
Addressable may appoint new Sub Processors and shall give prior notice of the appointment of any new Sub Processor (e.g., by e-mail), whether by general or specific reference to such Sub Processor (e.g., by name or type of service), including relevant details of the Processing to be undertaken by the new Sub Processor. If Customer notifies Addressable in writing of any objections (on reasonable grounds) to the proposed appointment within seven (7) days of such notice, Addressable shall not appoint the proposed Sub Processor for the Processing of Customer Personal Data until reasonable steps have been taken to address the objections raised by Customer, and Customer has been provided with a reasonable written explanation of the steps taken. Where such steps are not sufficient to relieve Customer’s reasonable objections then Customer or Addressable may, by written notice to the other Party, with immediate effect, terminate the Agreement to the extent that it relates to the Services which require the use of the proposed Sub Processor without bearing liability for such termination. Otherwise, Customer shall be deemed to have accepted such appointment.
With respect to each new Sub Processor, Addressable shall:
Take reasonable steps (for instance by way of reviewing privacy policies as appropriate) before the Sub Processor first Processes Customer Personal Data, to ensure that the Sub Processor is committed to providing the level of protection for Customer Personal Data required by the Agreement;
Ensure that the arrangement between Addressable and the Sub Processor is governed by a written contract, including terms which offer a materially similar level of protection for Customer Personal Data as those set out in this DPA and meet the requirements of Data Protection Laws; and
Remain fully liable to Customer for the performance of any and all Processing of Customer Personal Data performed by Sub Processor in connection with the specific Processing activities performed by Sub Processor on behalf of Customer.
8. Data Subject Rights
Customer shall be solely responsible for compliance with any statutory obligations concerning requests to exercise Data Subject rights under Data Protection Laws (e.g., for access, rectification, deletion of Customer Personal Data, etc.). After considering the nature of the Processing, Addressable shall reasonably endeavor to assist Customer insofar as feasible, to fulfill Customer’s said obligations with respect to such Data Subject requests, as applicable, at Customer’s sole expense.
Addressable shall:
Unless otherwise required under Applicable Laws, promptly notify Customer if it receives a request from a Data Subject under any Data Protection Law in respect of Customer Personal Data; and
Ensure that it does not respond to that request except on the documented instructions of Customer or as required by Applicable Laws to which the Addressable is subject, in which case Addressable shall, to the extent permitted by Applicable Laws, inform Customer of that legal requirement before it responds to the request.
9. Personal Data Breach
Addressable shall notify Customer without undue delay upon Addressable becoming aware of a Personal Data Breach either affecting or related to Addressable’s or Addressable’s Affiliates Processing of such Customer Personal Data. In such event, Addressable shall provide Customer with information (to the extent in Addressable’s possession) to assist Customer to meet any obligations to inform Data Subjects or data protection authorities of the Personal Data Breach under the Data Protection Laws.
At the written request and sole expense of the Customer, Addressable shall reasonably cooperate with Customer and take such commercially reasonable steps as are agreed by the Parties or necessary under Privacy Protection Laws to assist in the investigation, mitigation and remediation of each such Personal Data Breach.
10. Data Protection Impact Assessment and Prior Consultation
At the written request of the Customer, Addressable and each Addressable Affiliate shall provide reasonable assistance to Customer, at Customer’s expense, with any data protection impact assessments or prior consultations with Supervising Authorities or other competent data privacy authorities, as required under any applicable Data Protection Laws. Such assistance shall be solely in relation to Processing of Customer Personal Data by Addressable.
11. Deletion or return of Customer Personal Data
Subject to Section 11.2 below, Addressable shall promptly, but no later than sixty (60) days of the date of cessation of any Services involving the Processing of Customer Personal Data, delete or pseudonymize all copies of such Customer Personal Data, except any copies that are authorized to be retained under this DPA or required to be retained in accordance with Applicable Law and/or regulation.
Subject to the Agreement, Addressable may retain Customer Personal Data to the extent authorized or required by applicable laws, provided that Addressable shall ensure the confidentiality of all such Customer Personal Data and shall ensure that it is only Processed for such legal purpose(s).
Upon Customer’s prior written request, Addressable shall provide written certification to Customer that it has complied with this Section 11.
12. Audit Rights
Upon prior written request from the Customer, subject to Sections 12.2 and 12.3, and only to the extent required under applicable Data Protection Laws, Addressable shall coordinate to make available to a reputable independent auditor mandated by Customer such information necessary to reasonably demonstrate compliance with this DPA, and allow for audits, including inspections by such reputable auditor in relation to the Processing of the Customer Personal Data by Addressable, provided that such third-party auditor shall be subject to confidentiality obligations.
Provisions of information and audits shall be at Customer’s sole expense and may only arise under Section 12.1, but only to the extent that the Agreement does not otherwise give Customer any information and audit rights that meet the relevant requirements of the applicable Data Protection Laws. In any event, all audits or inspections shall be subject to the terms of the Agreement, and to Addressable’s obligations to third parties, including with respect to confidentiality.
Customer shall give Addressable reasonable prior written notice of any audit or inspection to be conducted under Section 12.1 and shall not cause (and ensure that each of its mandated auditors does not cause) any damage, injury or disruption to Addressable’s premises, equipment, personnel and business while its personnel are on those premises in the course of such an audit or inspection. Addressable need not give access to its premises for the purposes of such an audit or inspection if:
an individual fails to produce reasonable evidence of their identity and authority;
addressable was not given a written notice of such audit or inspection at least 2 weeks in advance;
the audit or inspection takes place outside normal business hours at those premises, unless the audit or inspection needs to be conducted on an emergency basis and Customer has given notice to Addressable that this is the case before attendance outside those hours begins; or
the audit or inspection is for a premises outside Addressable’s control (such as data storage farms of Addressable’s cloud hosting providers).
13. Restricted Transfers
Transfer of Customer Personal Data shall be carried out by Addressable in accordance with Applicable Laws. Addressable undertakes to ensure that the transfer of personal data outside the EU / EEA, Switzerland or the United Kingdom, to any country that has not been deemed adequate by the EU commission, is carried out on the basis of the applicable standard contractual clauses.
14. General Terms
Governing Law and Jurisdiction.
The Parties to this DPA hereby submit to the choice of jurisdiction stipulated in the Principal Agreement with respect to any disputes or claims howsoever arising under this DPA, including disputes regarding its existence, validity or termination or the consequences of its nullity.
This DPA and all non-contractual or other obligations arising out of or in connection therewith are governed by the laws of the country or territory stipulated for this purpose in the Principal Agreement.
Order of Precedence. Nothing in this DPA reduces Addressable’s obligations under the Agreement in relation to the protection of Personal Data or permits Addressable to Process (or permit the Processing of) Personal Data in a manner which is prohibited by the Agreement. In the event of any conflict or inconsistency between this DPA and the Principal Agreement, this DPA shall prevail solely with respect to the subject matter of this DPA and solely if such conflict or inconsistency originates from the requirements of Article 28 of the GDPR (except where explicitly agreed otherwise in writing, signed on behalf of the Parties). This DPA is not intended to, and does not in any way limit or derogate from Customer’s own obligations and liabilities towards Addressable under the Agreement, and/or pursuant to the GDPR or any law applicable to Customer, in connection with the collection, handling and use of Personal Data by Customer or its Affiliates or other processors or their sub-processors, including with respect to the transfer or provision or Personal Data to Addressable and/or providing access thereto to Addressable.
Changes in Data Protection Laws.
Customer may by at least forty-five (45) calendar days’ prior written notice to Addressable, request in writing any variations to this DPA if they are required, as a result of any change in, or decision of a competent authority under any applicable Data Protection Law, to allow Processing of those Customer Personal Data to be made (or continue to be made) without breach of that Data Protection Law.
If Customer gives notice with respect to its request to modify this DPA under Section 14.3.1:
Addressable shall make commercially reasonable efforts to accommodate such modification request; and
Customer shall not unreasonably withhold or delay agreement to any consequential variations to this DPA proposed by Addressable to protect the Addressable against additional risks, or to indemnify and compensate Addressable for any further steps and costs associated with the variations made herein.
If Customer gives notice under Section 14.3.1, the Parties shall promptly discuss the proposed variations and negotiate in good faith with a view to agreeing and implementing those or alternative variations designed to address the requirements identified in Customer’s notice as soon as is reasonably practicable. In the event that the Parties are unable to reach such an agreement within thirty (30) days, then Customer or Addressable may, by written notice to the other Party, with immediate effect, terminate the Agreement to the extent that it relates to the Services which are affected by the proposed variations (or lack thereof).
Severance. Should any provision of this DPA be deemed invalid or unenforceable, then the remainder of this DPA shall remain valid and in force. The invalid or unenforceable provision shall either be (i) amended as necessary to ensure its validity and enforceability, while preserving the Parties’ intentions as closely as possible or, if this is not possible, (ii) construed in a manner as if the invalid or unenforceable part had never been contained therein.
Subject Matter and Duration of the Processing of Customer Personal Data. Processing of Customer Personal Data for the purpose of and for the duration required for, enriching Customer’s information about data subjects, and at Customer’s option also providing marketing services to the Customer in accordance with the Agreement.
The Nature and Purpose of the Processing of Customer Personal Data:
Addressable’s data enrichment services: matching Customer’s data subjects to Addressable’s crypto identity graph to enrich the information you have about your data subjects.
If customer subscribes to Addressable’s marketing services: rendering marketing services to Customer in the nature of a software-as-a-service (SaaS) platform for digital marketing as detailed in the Principal Agreement.
The types of Customer Personal Data to be Processed are as follows:
Addressable’s data enrichment services:
Addressable online ID.
IP address (optional, at Customer’s choice).
Crypto wallet address (optional, at Customer’s choice).
PII hashed data (optional, at Customer’s choice): such as a hashed email address, phone number, device ID, or other hashed identifier.
The categories of Data Subjects to whom the Customer Personal Data relates to are as follows: Customer’s users, Customer’s prospects, Customer’s audiences.
The obligations and rights of Customer. The obligations and rights of Customer and Customer Affiliates are set out in the Agreement and this DPA.
Addressable maintains a layered security program covering access governance, encryption, data minimization, resilience, and independent third-party assurance. These measures are reviewed on an ongoing basis and are designed to meet the expectations of enterprise and regulated customers.
1. Access Control — Access to Customer Personal Data is governed by the principle of least privilege: only employees, affiliates, and service providers with a demonstrated need for access — for service delivery, security, compliance, or support — may obtain it. All access is authenticated via Single Sign-On (SSO) with mandatory multi-factor authentication (MFA), and permissions are assigned on a role-based basis, with access reviewed and revoked as roles change.
2. Encryption — Data is encrypted in transit using TLS/HTTPS; plaintext transmission is never permitted. Data at rest is encrypted using AWS object-level encryption, ensuring stored Customer Personal Data remains protected independent of network-layer controls.
3. Data Minimization — Addressable collects only the limited technical and device information necessary to deliver the enrichment service. Where Customer chooses to provide additional identifiers — such as a crypto wallet address or a hashed email or phone number — these are used exclusively for matching purposes and nothing further.
4. Retention & Deletion — Upon service termination, Customer Personal Data is anonymized or deleted as per Addressable’s retention policy. Data subject requests — access, correction, or deletion — are actioned without undue delay upon a valid request submitted to info@addressable.io, except where continued retention is required by law.
5. Network & Application Security — The enrichment integration is a lightweight, client-side component deployed by Customer on its own digital properties, operating with the minimum permissions necessary to perform matching and enrichment — it does not access or process information beyond that purpose. All data transmitted between the script and Addressable's backend is protected in transit via industry-standard HTTPS/TLS.
Backend processing is hosted on AWS infrastructure in the US East (N. Virginia) region; this transfer is covered by AWS's self-certification under the EU-U.S. Data Privacy Framework, with technical and organizational safeguards applied throughout.
6. Backup & Disaster Recovery — All internal databases and platform data are stored on AWS infrastructure, which itself is certified to SOC 2 Type II and ISO 27001:2013 standards. Addressable performs daily snapshot backups, retained for up to one year (with extended retention available on request), and its DevOps team regularly tests backup restoration to validate recovery readiness. The underlying data centers operate with N+1 redundancy to preserve service continuity in the event of component failure.
7. Independent Testing & Assurance — Addressable maintains SOC 2 Type II compliance, audited annually by EY, and undergoes independent third-party penetration testing on an annual basis (Explorisk), operating in alignment with GDPR principles throughout. Supporting audit documentation is available on request.
8. Sub-Processors — The only subprocessor for client data is Amazon Web Services, Inc., United States, as an infrastructure provider.
9. Data Subject Requests — Addressable supports data subject requests — access, correction, and deletion — submitted to info@addressable.io, actioned without undue delay absent a legal basis for continued retention.
