Data Processing Agreement

Effective from: October 2023

Updated: April 2026

This Data Processing Agreement ("DPA") is an integral part of the master Terms and Conditions ("Agreement") between Zintlr Private Limited ("Zintlr") and the Customer. Zintlr and the Customer shall hereafter be collectively referred to as the "Parties," and each individually as a "Party."

The Parties seek to implement this DPA to comply with the requirements of EU GDPR, the Digital Personal Data Protection Act, 2023 (DPDPA), UK GDPR, CCPA, and other applicable data protection laws concerning the Processor's processing of Personal Data as part of its obligations under the Agreement.

This DPA supersedes and replaces any existing data processing terms between the Parties. In case of any contradiction or conflict between the terms of this DPA and the Agreement, the terms of this DPA shall take precedence.

Definitions
For the purposes of this Data Processing Agreement ("DPA"), the following terms have the meanings set forth below. Capitalized terms used but not defined in this DPA shall have the meanings given in Applicable Data Protection Laws or the Agreement.
1. Agreement:
  The contractual arrangement between Zintlr and the Customer governing the Customer's subscription to the Services; here the Terms & Conditions Agreement between the Licensee, End-User, and Zintlr.
2. Applicable Data Protection Laws:
  The data protection laws and regulations applicable to the processing of Personal Data under this DPA, including: (a) EU GDPR and UK GDPR; (b) the Digital Personal Data Protection Act, 2023 (DPDPA) and its implementing rules as notified by the Government of India from time to time; (c) the California Consumer Privacy Act (CCPA) and its amendments; and (d) any other applicable national or state data protection laws relevant to the processing activities under this Agreement.
3. Controller / Data Fiduciary:
  The entity that determines how and why personal data is processed. In this case, the Customer/Licensee/End-user of Zintlr. Under DPDPA 2023, the Controller is referred to as the "Data Fiduciary." These terms are used interchangeably in this DPA.
4. Customer:
  The entity or individual that has entered into the Agreement with Zintlr for the provision of services.
5. Data Exporter:
  In the context of EU/UK GDPR transfers, the Data Exporter is the Customer (Controller), transferring personal data to Zintlr for processing.
6. Data Importer:
  In the context of EU/UK GDPR transfers, the Data Importer is Zintlr Private Limited, processing personal data as Processor on behalf of the Customer.
7. Data Principal / Data Subject:
  An identified or identifiable natural person whose personal data is being processed. Under DPDPA 2023, such persons are referred to as "Data Principals." Under GDPR, they are referred to as "Data Subjects." These terms are used interchangeably in this DPA.
8. Data Protection Board:
  The Data Protection Board of India established under Section 18 of the Digital Personal Data Protection Act, 2023, being the competent supervisory authority for processing of personal data of Indian data principals.
9. Data Transfer:
  A transfer of Personal Data from the Controller to the Processor, between two establishments of the Processor, or with a Sub-processor by the Processor.
10. DPDPA:
  The Digital Personal Data Protection Act, 2023, enacted by the Parliament of India, including all rules, regulations, and guidelines issued thereunder by the Central Government or the Data Protection Board of India from time to time.
11. EU GDPR:
  Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data (General Data Protection Regulation).
12. Personal Data:
  Information that can be linked to an individual and helps to identify or distinguish them from others. Under DPDPA, this refers to digital personal data as defined under Section 2(t) of the DPDPA.
13. Processing:
  Any operation or action that is taken with personal data, ranging from its collection to its eventual deletion or destruction.
14. Processor / Data Processor:
  A party that processes personal data on behalf of the Controller/Data Fiduciary, following their instructions and under their authority; here Zintlr Private Limited. Under DPDPA 2023, this role is referred to as "Data Processor." These terms are used interchangeably in this DPA.
15. Services:
  The provision of the Zintlr Platform (and any other hosted solutions or cloud products) by Zintlr to the Customer as specified in the Agreement.
16. Standard Contractual Clauses:
  The contractual clauses attached as Schedule 1 pursuant to the European Commission's Implementing Decision (EU) 2021/914 of 4 June 2021 on Standard Contractual Clauses for the transfer of Personal Data to processors in third countries.
17. Sub-processor:
  A processor/sub-contractor appointed by the Processor for the provision of all or parts of the Services who processes the Personal Data as provided by the Controller.
18. Supervisory Authority:
  An independent public authority responsible for monitoring and enforcing data protection laws. For this DPA: (a) for EU GDPR processing, the relevant EU member state supervisory authority; (b) for UK GDPR, the Information Commissioner's Office; and (c) for DPDPA 2023, the Data Protection Board of India.
Scope
Sections 3 to 8 of this DPA apply if and to the extent that Zintlr acts as a Data Processor for processing Personal Data received from the Customer, where the Customer is a Data Controller/Data Fiduciary subject to: (a) EU GDPR; (b) UK GDPR; (c) the Digital Personal Data Protection Act, 2023 (DPDPA); and/or (d) any other applicable data protection laws. Section 9 applies only if and to the extent that Zintlr acts as a "service provider" for processing Personal Information received from the Customer where the Customer is a Business subject to the CCPA.

Standard Contractual Clauses

These Standard Contractual Clauses ("SCCs") form an integral part of the agreement between the Data Exporter and the Data Importer, in compliance with the GDPR, CCPA, and DPDPA 2023.

Obligations of the Parties
1. The Data Importer shall inform the Data Exporter in writing of any intended changes to its list of sub-processors at least 30 (thirty) days in advance. The Data Exporter shall have the right to object to such changes within this notice period. If legitimate objections are raised, the Data Importer shall either refrain from using the objected sub-processor or provide notice of its intention to continue. The Data Exporter may terminate the agreement by providing written notice if it chooses to do so.
2. The Parties agree that disputes arising from the SCCs shall be subject to split jurisdiction: (a) for EU/UK data subjects, the jurisdiction of the relevant EU member state courts applicable under Clause 13 of the EU SCCs; and (b) for Indian data principals and all other matters, the courts of Bengaluru, India, under Indian law.
Description of Transfer
1. Data Exporter: Customer
  Activities: Organisation using Zintlr's services involving the processing of personal data.
  Role: Controller / Data Fiduciary.
2. Data Importer: Zintlr Private Limited
  Activities: Developer, operator, and provider of Zintlr's services.
  Role: Processor / Data Processor.

Data Categories

Field	Details
Categories of data subjects	Business professionals and companies; authorised users of the Customer's account.
Categories of personal data	Name, professional email, phone number, job title, employment information, company information, online identifiers, geographic information. For NBFC services: credit scores, digital footprint scores, city location.
Sensitive data	None for standard B2B contact data. Financial indicators for NBFC vertical only.
Frequency	Continuous basis.
Nature of processing	Recording, storage, consultation, use, disclosure by transmission, and erasure.
Purpose(s)	Provision of Zintlr's services as specified in the applicable Order Form and Agreement.
Retention period	The period of the Agreement. Zintlr may retain aggregated or anonymised data for statistical and financial purposes as permitted by applicable law.

Technical and Organizational Measures
Please refer to Section 12 below.
Assistance
Zintlr shall provide reasonable assistance to the Controller in fulfilling its obligations under applicable data protection laws at no additional charge. Where the Controller requests assistance that goes materially beyond standard compliance obligations and requires significant dedicated engineering or legal resources, the Parties shall agree on reasonable fees in advance of such assistance being provided.

Data Controller’s Obligations
1. The Data Controller warrants that it has all necessary rights to provide the Personal Data to the Data Processor. To the extent required by Applicable Data Protection Laws, the Data Controller is responsible for ensuring an appropriate legal basis for processing, obtaining any necessary consents from Data Principals/Data Subjects, maintaining records of such consents, and communicating any consent revocation to the Data Processor promptly.
2. The Data Controller shall provide all natural persons from whom it collects Personal Data with the relevant privacy notice.
3. The Data Controller shall request the Data Processor to purge Personal Data when required by the Data Controller or any Data Principal/Data Subject, unless the Data Processor is otherwise required to retain it by applicable law.
4. The Data Controller shall immediately advise the Data Processor in writing if it receives or learns of any:
  complaint or allegation indicating a violation of Data Privacy Laws;
  request from individuals seeking to access, correct, or delete Personal Data;
  inquiry or complaint relating to the collection, processing, use, or transfer of Personal Data; or
  any regulatory request, search warrant, or other governmental process seeking Personal Data.
5. Children's Data: The Customer warrants that it will not submit personal data of individuals under the age of 18 to Zintlr's platform. In the event the Customer becomes aware that such data has been submitted, it shall notify Zintlr immediately and request erasure. The Customer acknowledges that Zintlr's platform is not intended for and does not knowingly collect or process the personal data of minors.
Data Processor’s Obligations
1. The Processor will follow written and documented instructions received, including via email from designated authorised contacts of the Controller, with respect to the Processing of Personal Data. Instructions must originate from authorised representatives of the Controller and shall be logged in a documented instruction register maintained by Zintlr.
2. The Processing described in the Agreement and related documentation shall be considered as Instructions from the Controller.
3. At the Data Controller's request, the Data Processor will provide reasonable assistance to the Data Controller in responding to requests from Data Principals/Data Subjects exercising their rights under DPDPA 2023, GDPR, CCPA, and other applicable laws, including requests directed to Zintlr's Data Subject Rights portal at https://zintlr.com/privacy-center/. Zintlr shall acknowledge such requests within 72 hours and resolve them within 30 days of receipt.
4. In relation to Personal Data, the Data Processor shall obtain consent (where necessary) and/or provide notice to Data Principals/Data Subjects in accordance with Applicable Data Protection Laws. Where a Data Principal withdraws consent, Zintlr shall cease processing the relevant personal data within 30 days of being notified of such withdrawal by the Controller or the Data Principal directly.
5. Where shared Personal Data is transferred outside the Data Processor's territorial boundaries, the transferor shall ensure that the recipient is under contractual obligations to protect such Personal Data to the same or higher standards as this DPA and Applicable Data Protection Laws.
6. Storage Limitation: Zintlr shall not retain personal data submitted by the Customer beyond the period necessary for the purpose for which it was submitted. Where personal data submitted by the Customer is no longer required for its specified processing purpose during the term of the Agreement, Zintlr shall delete or anonymise such data as soon as reasonably practicable.
7. Data Accuracy: Zintlr shall take reasonable steps to ensure that personal data in its database is accurate and, where necessary, kept up to date. Zintlr does not warrant the absolute accuracy of data sourced from third parties or public sources. The Customer is responsible for independently verifying data accuracy before using it for decisions that carry material consequences, including credit decisions, financial assessments, or any decisions regulated by IRDAI or RBI.
8. Children's Data: Zintlr shall not knowingly process personal data of individuals under the age of 18. Upon becoming aware of such data in its systems, Zintlr shall promptly delete it and notify the Controller.
Audits
1. Upon Controller's reasonable request, the Processor will make available to the Controller information as is reasonably necessary to demonstrate the Processor's compliance with its obligations under EU GDPR, DPDPA 2023, or other applicable laws.
2. When the Controller wishes to conduct an audit at the Processor's site, it shall provide at least 30 (thirty) days' prior written notice. The Processor will provide reasonable cooperation and assistance.
3. Audit Costs: The Controller shall bear the expense of routine compliance audits. Where an audit reveals material non-compliance by Zintlr with its obligations under this DPA, Zintlr shall bear the reasonable costs of that audit.
Data Secrecy
To Process the Personal Data, the Processor will use personnel who are
1. Informed of the confidential nature of the Personal Data, and
2. Perform the Services in accordance with the Agreement.
The Processor will regularly train individuals having access to Personal Data in data security and data privacy in accordance with accepted industry practice and shall ensure that all the Personal Data is kept strictly confidential.
The Processor will maintain appropriate technical and organizational measures for protection of the security, confidentiality, and integrity of the Personal Data as per the specifications as per the standards mutually agreed in writing by the Parties.
Mechanism of Data Transfers
Any Data Transfer for the purpose of Processing by the Processor in a country outside the European Economic Area (the “EEA”) shall only take place in compliance with Schedule 1 to this DPA.
Cross-Border Transfers — DPDPA 2023: Zintlr shall not transfer personal data of Indian data principals to any country outside India except to countries permitted under Section 16 of the DPDPA 2023, as notified by the Central Government from time to time. Pending formal notification of permitted countries, Zintlr shall ensure that any cross-border transfer of Indian personal data is subject to contractual obligations on the recipient that are functionally equivalent to those under this DPA and DPDPA 2023. Zintlr shall update its sub-processor agreements and transfer mechanisms accordingly as DPDPA transfer rules are notified.
Cross-Border Transfers — EU/UK GDPR: Transfers of personal data of EU or UK data subjects shall be made in accordance with the Standard Contractual Clauses set out in Schedule 1. Where SCCs are updated or replaced by the European Commission or UK authorities, Zintlr shall adopt the updated clauses within the timeframe required by applicable law.
Cross-Border Transfers — Other Jurisdictions: Where personal data of residents of jurisdictions other than India, the EU, UK, and USA is processed, Zintlr shall comply with applicable data protection laws of the relevant jurisdiction to the extent they apply to Zintlr as a Data Processor.
Sub-processors
1. The Controller acknowledges and agrees that the Processor may engage third-party Sub-processors in connection with the performance of the Services, provided such Sub-processors are bound by data protection obligations functionally equivalent to those under this DPA and applicable law, including DPDPA 2023. For Sub-processors handling personal data of Indian data principals, Zintlr shall ensure such Sub-processors are bound by DPDPA-equivalent protections or are GDPR-compliant, which shall serve as a functionally equivalent standard pending formal DPDPA transfer rule notification. The current approved Sub-processors are listed in Annex III of Schedule 1. In accordance with Article 28(4) of the GDPR, the Processor shall remain liable to the Controller for any failure of a Sub-processor to fulfil its data protection obligations under this DPA.
2. The Data Importer shall inform the Data Exporter in writing of any intended changes to its list of sub-processors at least 30 (thirty) days in advance. If the Controller objects to a new sub-processor within the 30-day notice period, the Parties shall confer in good faith to address the concern.
Personal Data Breach Notification
1. The Processor shall maintain defined procedures in case of a Personal Data Breach and shall notify the Controller within 72 (seventy-two) hours of becoming aware of any Personal Data Breach likely to result in a risk to the rights and freedoms of natural persons or Data Principals. Such notification shall include: (a) the nature of the breach; (b) categories and approximate number of data principals/subjects affected; (c) categories and approximate number of personal data records affected; (d) the likely consequences of the breach; and (e) measures taken or proposed to address the breach.
2. The Processor shall provide the Controller with all reasonable assistance to comply with the notification of a Personal Data Breach to the Data Protection Board of India, relevant EU/UK supervisory authorities, and/or the Data Principal/Data Subject, to identify the cause of such breach, and to take commercially reasonable steps to mitigate and remedy such breach.
3. The Processor shall provide a full written incident report to the Controller within 30 (thirty) days of the initial breach notification, covering root cause analysis, remediation steps, and confirmation of data affected.
4. No Acknowledgement of Fault: The Processor's notification of or response to a Personal Data Breach under this DPA will not be construed as an acknowledgement by the Processor of any fault or liability with respect to the data incident.
Return and Deletion of Personal Data
1. The Processor shall at least thirty (30) days from the end of the Agreement or cessation of the Processor’s Services under the Agreement, whichever occurs earlier, shall return to the Controller all the Personal Data, or if the Controller so instructs, the Processor shall have the Personal Data deleted. The Processor shall return such Personal Data in a commonly used format or in the current format in which it was stored at discretion of the Controller, soon as reasonably practicable following receipt of Controller’s notification.
2. In any case, the Processor shall delete Personal Data including all the copies of it as soon as reasonably practicable following the end of the Agreement.
3. Upon termination, Zintlr shall return any personal data uploaded by the Customer into the platform (including enrichment lists and other Customer-submitted data) within 30 days of written request, in the format in which it was submitted.
Technical and Organizational Measures
Having regard to the state of technological development and the cost of implementing any measures, the Processor will take appropriate technical and organizational measures against the unauthorized or unlawful processing of Personal Data and against the accidental loss or destruction of, or damage to, Personal Data to ensure a level of security appropriate to: (a) the harm that might result from unauthorized or unlawful processing or accidental loss, destruction or damage; and (b) the nature of the data to be protected [including the measures stated in Annex II of Schedule 1].
Legal Basis
The Customer shall ensure that all Personal Data processed through the Zintlr Service is done so in accordance with a valid and recognised lawful basis as required by EU GDPR, DPDPA 2023, CCPA, and other Applicable Data Protection Laws. The Customer is responsible for providing Zintlr with lawful instructions that comply with the provisions of these regulations and do not impose any obligation on Zintlr that would result in a breach of applicable law.
Additional Safeguards — Government Authority Requests
Zintlr acknowledges and assures the implementation and maintenance of a comprehensive procedure to review and respond to any requests, orders, or demands from government authorities or regulatory bodies of any jurisdiction — including Indian government authorities, non-EEA government authorities, and any law enforcement or intelligence agencies — seeking access to or disclosure of personal data ("Government Authority Requests"). This procedure includes the following commitments:
1. Promptly notifying the Customer in writing, within the bounds of applicable law, upon receipt of a Government Authority Request, enabling the Customer to contest, limit, or seek appropriate legal remedies. Zintlr will make reasonable efforts to redirect the requesting authority to obtain the requested personal data directly from the Customer, where permitted by applicable law.
2. Providing reasonable assistance as required by the Customer in responding to the Government Authority Request, subject to applicable law.
3. Promptly notifying the Data Principal/Data Subject (if their identity is known) of the Government Authority Request, in compliance with applicable law.
4. If prohibited by applicable law from notifying the Customer, making reasonable efforts to obtain permission to allow the Customer to intervene in the proceedings and challenge any request that is not legally binding or lawful. No information will be disclosed until a competent court has issued an unchallengeable legal order.
5. If contesting or seeking limitations on the Government Authority Request is unsuccessful, taking reasonable steps to ensure that any disclosed personal data is proportionate and limited to the minimum necessary.
6. Promptly informing the Customer if any Government Authority Request or subsequent actions prevent Zintlr from complying with the obligations outlined in this DPA or the Customer's instructions.
Zintlr commits to maintaining written records, to the extent permitted by applicable law, including details of the authority making the Government Authority Request, the number of requests received, Zintlr's response, the types of personal data provided, and the number of data principals/subjects affected. Upon request, and subject to applicable law, Zintlr will provide aggregated information from these records to the Customer.
Security Measures
Security Measures refer to reasonable and appropriate security-related policies, standards, and practices implemented by Zintlr.
1. Zintlr commits to implementing Security Measures to safeguard the availability, confidentiality, and integrity of any Personal Data collected, accessed, or processed in connection with this Agreement, as detailed in Annex II of Schedule 1.
2. The Security Measures may be subject to updates and modifications to reflect technological advancements. Such changes will not compromise the overall security of the services provided to the Customer.
3. Zintlr will take reasonable measures to ensure the trustworthiness of its staff who have access to Personal Data. Authorised personnel have committed to maintaining confidentiality or are bound by relevant legal obligations of confidentiality.
CCPA
As a Service Provider, Zintlr is strictly prohibited from retaining, using, or disclosing the Customer's Personal Information for purposes other than those defined in the Agreement. Zintlr's permitted use of Personal Information is limited to searching the Zintlr database for information about a Contact as requested by the Customer, or as otherwise allowed under applicable regulations.
Zintlr is explicitly prohibited from selling the Customer's Personal Information or using or disclosing it outside of the direct business relationship between the Parties, except as permitted under relevant applicable law.
Changes
Zintlr reserves the right to modify this DPA if necessary to comply with Applicable Data Protection Laws, court orders, or guidance provided by governmental regulators or agencies. However, any changes made by Zintlr shall not:
1. alter the classification of Zintlr as the Data Processor;
2. expand the scope of either Party's rights to process Personal Data or remove any existing restrictions; or
3. have a significant adverse impact on the Customer, as reasonably determined by Zintlr.
In the event that Zintlr intends to make changes to this DPA and such changes are expected to have a material adverse impact on the Customer, Zintlr will make commercially reasonable efforts to notify the Customer at least 30 days in advance. Where compliance with applicable laws necessitates a shorter notice period, Zintlr will adhere to the required timeframe before implementing the changes.
Objection Process: Where the Customer raises a written objection to a proposed change within the notice period, the Parties shall discuss the objection in good faith. If no resolution is reached within 15 days of the objection being raised, the existing terms shall continue to govern until the Parties agree or until Zintlr is legally required to implement the change, whichever is earlier.
Downstream Use Restriction
Personal data purchased, accessed, or obtained through Zintlr's Services may only be used by the Customer for legitimate B2B sales, marketing, and business intelligence purposes. The Customer expressly agrees that it shall not use Zintlr's data for: (a) retail consumer solicitation or direct-to-consumer marketing; (b) insurance product marketing or solicitation regulated by IRDAI, unless Zintlr has provided prior written consent for such use; (c) any purpose regulated by TRAI's DND or NDNC frameworks, without ensuring compliance with such regulations; (d) credit scoring, lending decisions, or financial product marketing regulated by RBI, unless covered by a specific Order Form for Zintlr's NBFC-specific data products; or (e) any purpose that violates applicable data protection laws or the rights of Data Principals/Data Subjects.
The Customer shall be solely liable for any regulatory action, complaint, or penalty arising from use of Zintlr's data in violation of this clause. Zintlr shall not be liable for misuse of its data by the Customer or any downstream recipient.
Purpose of Data Processing
Zintlr shall process personal data only for the purposes specified in the applicable Order Form and Agreement. The specific processing purposes, data categories, and permitted uses applicable to each Customer shall be as set out in the Order Form executed between the Parties. In the event of any conflict between this DPA and an Order Form regarding processing purposes, the Order Form shall prevail for that specific Customer engagement.
Data Principal Rights
Data Principals and Data Subjects have the following rights under applicable data protection laws, including DPDPA 2023 and GDPR: (a) right to access information about their personal data being processed; (b) right to correction and erasure of inaccurate or incomplete data; (c) right to withdraw consent for processing; (d) right to grievance redressal; and (e) such other rights as notified under applicable law from time to time.
Zintlr maintains a dedicated Data Subject Rights portal at https://zintlr.com/privacy-center/ through which Data Principals may search for their data, request rectification, and request erasure. Zintlr shall action any verified request received through this portal or notified by the Controller within 30 days.
Where the Controller receives a request from a Data Principal exercising rights under DPDPA 2023 or applicable law, Zintlr shall provide reasonable assistance to the Controller in responding to such request within 72 hours of being notified, and shall action any verified erasure or correction request within 30 days.

Grievance Officer

In accordance with the Digital Personal Data Protection Act, 2023, Zintlr has designated a Grievance Officer to address complaints and queries from Data Principals and Controllers. Zintlr shall acknowledge grievances within 48 hours and resolve them within 30 days.

Name:	Pranay Khariwal
Designation:	Authorised Signatory / Grievance Officer
Email:	[email protected]
Address:	3rd Floor, No. 38, GKR Sapthagiri Vaishtadhama, 12th Cross, off CBI Main Road, Ganganagar, Bengaluru, Karnataka 560032
Acknowledgement Timeline:	48 hours
Resolution Timeline:	30 days from receipt of grievance

Liability
Each Party's liability under this DPA shall be subject to the limitations and exclusions set out in the Agreement (Master Terms and Conditions / MSA) between the Parties. Nothing in this DPA shall expand the liability of either Party beyond the limits established in the Agreement.
Interpretation — DPDPA and GDPR Terminology
Where this DPA uses the term "Controller," it shall be read to include "Data Fiduciary" as defined under DPDPA 2023 in the context of Indian data processing. Where this DPA uses the term "Data Subject," it shall be read to include "Data Principal" as defined under DPDPA 2023. Where this DPA uses the term "Processor," it shall be read to include "Data Processor" as defined under DPDPA 2023. These equivalences are established for interpretive clarity and do not alter the substantive obligations of either Party.

SCHEDULE 1

ANNEX I

A. LIST OF PARTIES

Data exporter(s):

Name:	Customer (as defined in Agreement)
Address:	As set forth in the relevant Order Form.
Contact person:	As set forth in the relevant Order Form.
Activities relevant to the data transferred under these Clauses:	Organisation using Zintlr's services involving the processing of personal data.
Signature and date	Set out in the Agreement.
Role (Controller/ Processor):	Controller / Data Fiduciary

Data importer(s):

Name:	Zintlr Private Limited
Address:	3rd Floor, No. 38, GKR Sapthagiri Vaishtadhama, 12th Cross, off CBI Main Road, Ganganagar, Bengaluru, Karnataka 560032
Contact person:	Pranay Khariwal, [email protected]
Activities relevant to the data transferred under these Clauses:	Developer, operator, and provider of Zintlr's services involving the processing of personal data received from the Customer.
Signature and date	Set out in the Agreement.
Role (Controller/ Processor):	Processor / Data Processor

B. DESCRIPTION OF TRANSFER

Categories of data subjects whose personal data is transferred	Customer's authorised users of the Services; business professionals and companies in the Zintlr database.
Categories of personal data transferred	Names, email addresses, phone numbers, job titles, employment information, company information, online identifiers, geographic information. For NBFC services: credit scores, digital footprint scores.
Sensitive personal data transferred	None for standard B2B contact data. Financial indicators for NBFC vertical only.
Frequency of the transfer	Continuous.
Nature of the processing	Querying, enrichment, storage, and delivery of B2B contact and intelligence data as part of the provision of Services to Customer.
Purpose(s) of the data transfer and further processing	Provision of Zintlr's Services as specified in the applicable Order Form and Agreement.
Period for which the personal data will be retained or criteria used to determine that period	As described in the Agreement and applicable Order Forms.
Subprocessor transfers – subject matter, nature, and duration of processing	As described in Annex III below.

C. COMPETENT SUPERVISORY AUTHORITY

Updated to include the Data Protection Board of India as competent supervisory authority for DPDPA 2023.

Jurisdiction	Competent Supervisory Authority	Reference
EU GDPR	As determined by Clause 13 of the EU SCCs, based on the EU member state of the Data Exporter.	EU SCCs Clause 13
UK GDPR	Information Commissioner's Office (ICO), United Kingdom.	UK GDPR Art. 4(21)
DPDPA 2023 (India)	The Data Protection Board of India, established under Section 18 of the Digital Personal Data Protection Act, 2023.	DPDPA 2023 S.18
Other jurisdictions	As determined by applicable local data protection law.	N/A

ANNEX II

TECHNICAL AND ORGANISATIONAL MEASURES INCLUDING TECHNICAL AND ORGANISATIONAL MEASURES TO ENSURE THE SECURITY OF THE DATA

Description of the technical and organizational security measures implemented by Zintlr Private Limited as the data processor/data importer to ensure an appropriate level of security, taking into account the nature, scope, context, and purpose of the processing, and the risks for the rights and freedoms of natural persons.

Security

Security Management System:
1. Organization:
  Zintlr Private Limited designates qualified security personnel whose responsibilities include development, implementation, and ongoing maintenance of the Information Security Program.
2. 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.
3. Assessments:
  Zintlr Private Limited engages a reputable independent third-party to perform risk assessments of all systems containing Customer Personal Data at least once annually.
4. Risk Treatment:
  Zintlr Private Limited maintains a formal and effective risk treatment program that includes penetration testing, vulnerability management and patch management to identify and protect against potential threats to the security, integrity or confidentiality of Customer Personal Data.
5. Vendor Management:
  Zintlr Private Limited maintains an effective vendor management program.
6. Incident Management:
  Zintlr Private Limited reviews security incidents regularly, including effective determination of root cause and corrective action.
7. Standards:
  Zintlr Private Limited operates an information security management system that complies with the requirements of ISO/IEC 27001:2022 standard.
Personnel Security:
1. Zintlr Private Limited personnel are required to conduct themselves in a manner consistent with the company’s guidelines regarding confidentiality, business ethics, appropriate usage, and professional standards. Zintlr Private Limited 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, customary practice and statutory regulations.
2. 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 must acknowledge receipt of, and compliance with, Zintlr Private Limited’s confidentiality, privacy and security policies. Personnel are provided with privacy and security training on how to implement and comply with the Information Security Program. Personnel handling Customer Personal Data are required to complete additional requirements appropriate to their role (e.g., certifications). Zintlr Private Limited’s personnel will not process Customer Personal Data without authorization.
Access Controls:
1. Access Management:
  Zintlr Private Limited maintains a formal access management process for the request, review, approval and provisioning of all personnel with access to Customer Personal Data to limit access to Customer Personal Data and systems storing, accessing or transmitting Customer Personal Data to properly authorized persons having a need for such access. Access reviews are conducted at least quarterly to ensure that only those personnel with access to Customer Personal Data still require it.
2. Infrastructure Security Personnel:
  Zintlr Private Limited has, and maintains, a security policy for its personnel, and requires security training as part of the training package for its personnel. Zintlr Private Limited’s infrastructure security personnel are responsible for the ongoing monitoring of Zintlr Private Limited’s security infrastructure, the review of the Services, and for responding to security incidents.
3. Access Control and Privilege Management:
  Zintlr Private Limited’s and Customer’s 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.
4. Internal Data Access Processes and Policies – Access Policy:
  Zintlr Private Limited’s internal data access processes and policies are designed to protect against unauthorized access, use, disclosure, alteration or destruction of Customer Personal Data. Zintlr Private Limited 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”, and to prevent others who should not have access from obtaining access. Zintlr Private Limited requires the use of unique user IDs, strong passwords, two factor authentication and carefully monitored access lists to minimize the potential for unauthorized account use. The granting or modification of access rights is based on: the authorized personnel’s job responsibilities; job duty requirements necessary to perform authorized tasks; a need to know basis; and must be in accordance with Zintlr Private Limited’s internal data access policies and training. Approvals are managed by workflow tools that maintain audit records of all changes. Access to systems is logged to create an audit trail for accountability. Where passwords are employed for authentication (e.g., login to workstations), password policies follow industry standard practices. These standards include password complexity, password expiry, password lockout, restrictions on password reuse and re-prompt for password after a period of inactivity.
Data Center:
1. Infrastructure:
  Zintlr Private Limited has GCP as its data center.
2. Resiliency:
  Multi Availability Zones are enabled on GCP and Zintlr Private Limited conducts Backup Restoration Testing on regular basis to ensure resiliency.
3. Server Operating Systems:
  Zintlr Private Limited’s servers are customized for the application environment and the servers have been hardened for the security of the Services. Zintlr Private Limited employs a code review process to increase the security of the code used to provide the Services and enhance the security products in production environments.
4. Disaster Recovery:
  Zintlr Private Limited replicates data over multiple systems to help to protect against accidental destruction or loss. Zintlr Private Limited has designed and regularly plans and tests its disaster recovery programs.
5. Security Logs:
  Zintlr Private Limited’s systems have logging enabled to their respective system log facility in order to support the security audits, and monitor and detect actual and attempted attacks on, or intrusions into, Zintlr Private Limited’s systems.
6. Vulnerability Management:
  Zintlr Private Limited performs regular vulnerability scans on all infrastructure components of its production and development environment.  Vulnerabilities are remediated on a risk basis, with Critical, High and Medium security patches for all components installed as soon as commercially possible.
Networks, Transmission, and Encryption:
1. Data Transmission:
  Production environment transmissions via Internet standard protocols.
2. Firewall:
  GCP Security Groups (virtual firewall) in place for the production environment.
3. Incident Response:
  Zintlr Private Limited maintains incident management policies and procedures, including detailed security incident escalation procedures. Zintlr Private Limited monitors a variety of communication channels for security incidents, and Zintlr Private Limited security personnel will react promptly to suspected or known incidents, mitigate harmful effects of such security incidents, and document such security incidents and their outcomes.
4. Encryption:
  HTTPS/TLS encryption for all data in transit.
Data Storage, Isolation, and Destruction:
Data stored in a multi-tenant environment on GCP servers, replicated between multiple availability zones. Customer data is logically isolated. Central authentication used across all Services. Secure data destruction processes are in place.

ANNEX III

LIST OF SUB-PROCESSORS

Duplicate entry for Stripe has been removed. Each unique sub-processor is listed once below. The controller has authorized the use of the following sub-processors:

Name of Sub-Processor	Description of Processing	Location of Sub-Processor
Stripe	Payment Gateway	USA
Razorpay	Payment Gateway	India
Microsoft Clarity	Product Analytics	USA
Google Analytics	Product Analytics	USA
MixPanel	Product Analytics	USA
HubSpot	CRM Solution	USA
Google Ads	Advertisements	USA
Facebook Pixel	Advertisements	USA
Google Tag Manager	Insights / Tag Management	USA
Partenero	Affiliate Commission Tracking	Switzerland
Google reCAPTCHA	Risk Analysis	USA
Cloudflare	Risk Analysis / CDN	USA
Google Firebase	User Authentication	USA
Brevo	Email Services	USA
Gmail	Email Services	USA
Amazon Web Services	Cloud Platform	USA