DPA ACCESSION AGREEMENT

This DPA accession agreement is for entering into Data Processing Agreement (“DPA”) publicly available at https://yandex.com/legal/dpa.

1. THE ROLE OF EACH PARTY

as data controller or data processor

Controller(s): Processor(s):
Name Name
Address Address
Contact person’s name, position and contact details Contact person’s name, position and contact details

2. DESCRIPTION OF THE PROCESSING

Categories of data subjects whose personal data is processed
Categories of personal data processed

Sensitive data processed (if applicable) and applied restrictions or safeguards that fully take into consideration the nature of the data and the risks involved, such as for instance strict purpose limitation, access restrictions (including access only for staff having followed specialised training), keeping a record of access to the data, restrictions for onward transfers or additional security measures.

Nature of the processing

Purpose(s) for which the personal data is processed on behalf of the controller

Duration of the processing

For processing by (sub-) processors, also specify subject matter, nature and duration of the processing

3. TECHNICAL AND ORGANISATIONAL MEASURES

Technical and organisational security measures implemented by the processor(s) (including any relevant certifications) to ensure an appropriate level of security, taking into account the nature, scope, context and purpose of the processing, as well as the risks for the rights and freedoms of natural persons.

Measures of pseudonymisation and encryption of personal data
Measures for ensuring ongoing confidentiality, integrity, availability and resilience of processing systems and services
Measures for ensuring the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident
Processes for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures in order to ensure the security of the processing
Measures for user identification and authorization
Measures for the protection of data during transmission
Measures for the protection of data during storage
Measures for ensuring physical security of locations at which personal data are processed
Measures for ensuring events logging
Measures for ensuring system configuration, including default configuration
Measures for internal IT and IT security governance and management
Measures for certification/assurance of processes and products
Measures for ensuring data minimisation
Measures for ensuring data quality
Measures for ensuring limited data retention
Measures for ensuring accountability
Measures for allowing data portability and ensuring erasure] For transfers to (sub-) processors, alsodescribe the specific technical and organisational measures to be taken by the (sub-) processor to be able to provide assistance to the controller
Description of the specific technical and organisational measures to be taken by the processor to be able to provide assistance to the controller.

4. LIST OF SUB-PROCESSORS

The controller has authorised the use of the following sub-processors:

1 Name
Address
Contact person’s name, position and contact details
Description of the processing (including a clear delimitation of responsibilities in case several sub-processors are authorised)
2 Name
Address
Contact person’s name, position and contact details
Description of the processing (including a clear delimitation of responsibilities in case several sub-processors are authorised)
3 Name
Address
Contact person’s name, position and contact details
Description of the processing (including a clear delimitation of responsibilities in case several sub-processors are authorised)

5. SIGNATURES

Controller Processor
Name Name
Signature Signature
Accession date Accession date

Date of publication: 06.09.2021