RisingWave DPA 1

RisingWave Data Processing Addendum

This Data Processing Addendum (“DPA”) supplements the RisingWave Cloud Terms or similar commercial agreement

between the parties (the “Agreement”) entered into by and between [Customer, Inc.] (“Customer”) and SINGULARITY

DATA LIMITED, A DELAWARE CORPORATION, DBA RISINGWAVE LABS (“Company”). By executing the DPA in

accordance with Section 11 herein, Customer enters into this DPA on behalf of itself and, to the extent required under

applicable Data Protection Laws (defined below), in the name and on behalf of its Affiliates (defined below), if any.

This DPA incorporates the terms of the Agreement, and any terms not defined in this DPA shall have the meaning set

forth in the Agreement.

1. Definitions

1.1 “Affiliate” means (i) an entity of which a party directly or indirectly owns fifty percent (50%) or more of the

stock or other equity interest, (ii) an entity that owns at least fifty percent (50%) or more of the stock or other equity

interest of a party, or (iii) an entity which is under common control with a party by having at least fifty percent (50%)

or more of the stock or other equity interest of such entity and a party owned by the same person, but such entity

shall only be deemed to be an Affiliate so long as such ownership exists.

1.2 “Sub-Processor” means a third-party who has a need to know or otherwise access Customer’s Personal Data

to enable Company to perform its obligations under this DPA or the Agreement.

1.3 “Company Account Data” means personal data that relates to Company’s relationship with Customer,

including the names or contact information of individuals authorized by Customer to access Customer’s account and

billing information of individuals that Customer has associated with its account. Company Account Data also includes

any data Company may need to collect for the purpose of managing its relationship with Customer, identity

verification, or as otherwise required by applicable laws and regulations.

1.4 “Company Usage Data” means Service usage data collected and processed by Company in connection with

the provision of the Services, including without limitation data used to identify the source and destination of a

communication, activity logs, and data used to optimize and maintain performance of the Services, and to investigate

and prevent system abuse.

1.5 “Data Exporter” means Customer.

1.6 “Data Importer” means Company.

1.7 “Data Protection Laws” means any applicable laws and regulations in any relevant jurisdiction relating to the

use or processing of Personal Data including: (i) the California Consumer Privacy Act, as amended by the California

Privacy Rights Act of 2020 (“CPRA”); (ii) the General Data Protection Regulation (Regulation (EU) 2016/679) (“EU

GDPR”) and the EU GDPR as it forms part of the law of England and Wales by virtue of section 3 of the European Union

(Withdrawal) Act 2018 (the “UK GDPR”) (together, collectively, the “GDPR”); (iii) the Swiss Federal Act on Data

Protection, (iv) the UK Data Protection Act 2018; (v) the Privacy and Electronic Communications (EC Directive)

Regulations 2003; and (vi) the Virginia Consumer Data Protection Act (“VCDPA”); in each case, as updated, amended

or replaced from time to time. The terms “Data Subject”, “Personal Data”, “Personal Data Breach”, “processing”,

“processor, “controller,” and “supervisory authority” shall have the meanings set forth in the GDPR.

1.8 “EU SCCs” means the standard contractual clauses approved by the European Commission in Commission

Decision 2021/914 dated 4 June 2021, for transfers of personal data to countries not otherwise recognized as offering

an adequate level of protection for personal data by the European Commission (as amended and updated from time

to time), as modified by Section 6.2 of this DPA.

1.9 “ex-EEA Transfer” means the transfer of Personal Data, which is processed in accordance with the GDPR, from

the Data Exporter to the Data Importer (or its premises) outside the European Economic

Area (the “EEA”), and such transfer is not governed by an adequacy decision made by the European Commission in

accordance with the relevant provisions of the GDPR.

1.10 “ex-UK Transfer” means the transfer of Personal Data covered by Chapter V of the UK GDPR, which is

processed in accordance with the UK GDPR and the Data Protection Act 2018, from the Data Exporter to the Data

Importer (or its premises) outside the United Kingdom (the “UK”), and such transfer is not governed by an adequacy

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decision made by the Secretary of State in accordance with the relevant provisions of the UK GDPR and the Data

Protection Act 2018.

1.11“Services” shall have the meaning set forth in the Agreement.

1.12 “Standard Contractual Clauses” means the EU SCCs and the UK SCCs.

1.13“UK Addendum” has the meaning set forth in Attachment D.

1.14“UK SCCs” means the EU SCCs, as amended by the UK Addendum.

2. Relationship of the Parties; Processing of Data

2.1 The parties acknowledge and agree that with regard to the processing of Personal Data, Customer may act

either as a controller or processor and, except as expressly set forth in this DPA or the Agreement, Company is a

processor. Customer shall, in its use of the Services, at all times process Personal Data, and provide instructions for

the processing of Personal Data, in compliance with Data Protection Laws. Customer shall ensure that the processing

of Personal Data in accordance with Customer’s instructions will not cause Company to be in breach of the Data

Protection Laws. Customer is solely responsible for the accuracy, quality, and legality of (i) the Personal Data provided

to Company by or on behalf of Customer, (ii) the means by which Customer acquired any such Personal Data, and (iii)

the instructions it provides to Company regarding the processing of such Personal Data. Customer shall not provide or

make available to Company any Personal Data in violation of the Agreement or otherwise inappropriate for the nature

of the Services, and shall indemnify Company from all claims and losses in connection therewith. Any claims against

the Company or its Affiliates under this DPA shall be brought solely against the entity that is a party to the Agreement.

Except with respect to any enforcement rights afforded to Data Subjects under Data Protection Laws, no one other

than a party to this DPA, its successors and permitted assignees shall have any right to enforce any of its terms. In

addition to all other remedies available to Company, Customer further agrees that any regulatory penalties incurred

by Company in relation to any Customer Personal Data that arise as a result of, or in connection with, Customer’s

failure to comply with its obligations under this DPA or any applicable Data Protection Laws shall count toward and

reduce the Company’s liability under the Agreement as if it were liability to the Customer under the Agreement.

2.2 Company shall not process Personal Data (i) for purposes other than those set forth in the Agreement and/or

Attachment A, (ii) in a manner inconsistent with the terms and conditions set forth in this DPA or any other

documented instructions provided by Customer, including with regard to transfers of personal data to a third country

or an international organization, unless required to do so by Supervisory Authority to which the Company is subject;

in such a case, the Company shall inform the Customer of that legal requirement before processing, unless that law

prohibits such information on important grounds of public interest, or (iii) in violation of Data Protection Laws.

Customer hereby instructs Company to process Personal Data in accordance with the foregoing and as part of any

processing initiated by Customer in its use of the Services.

2.3 The subject matter, nature, purpose, and duration of this processing, as well as the types of Personal Data

collected and categories of Data Subjects, are described in Attachment A to this DPA.

2.4 Following completion of the Services, Company shall return or delete Customer’s Personal Data, as feasible,

unless further storage of such Personal Data is required or authorized by applicable law. If return or destruction is

impracticable or prohibited by law, rule or regulation, Company shall take measures to block such Personal Data from

any further processing (except to the extent necessary for its continued hosting or processing required by law, rule or

regulation) and shall continue to appropriately protect the Personal Data remaining in its possession, custody, or

control. If Customer and Company have entered into Standard Contractual Clauses as described in Section 6 (Transfers

of Personal Data), the parties agree that the certification of deletion of Personal Data that is described in Clause 8.1(d)

and Clause 8.5 of the EU SCCs (as applicable) shall be provided by Company to Customer only upon Customer’s request.

2.5 CPRA and VCDPA. The parties acknowledge and agree that the processing of personal information or personal

data that is subject to the CPRA or VCDPA shall be carried out in accordance with the terms set forth in Attachment E.

3. Confidentiality

Company shall ensure that any person it authorizes to process Personal Data has agreed to protect Personal Data in

accordance with Company’s confidentiality obligations in the Agreement. Customer agrees that Company may disclose

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Personal Data to its advisers, auditors or other third parties as reasonably required in connection with the performance

of its obligations under this DPA, the Agreement, or the provision of Services to Customer.

4. Sub-Processors

4.1 Customer acknowledges and agrees that Company may (1) engage its Affiliates as well as the Sub-Processors

to access and process Personal Data in connection with the Services and (2) from time to time engage additional third

parties for the purpose of providing the Services, including without limitation the processing of Personal Data. By way

of this DPA, Customer provides general written authorization to Company to engage sub-processors as necessary to

perform the Services.

4.2 Company will enter into a written agreement with the Sub-Processor imposing on the Sub-Processor data

protection obligations comparable to those imposed on Company under this DPA with respect to the protection of

Personal Data. In case a Sub-Processor fails to fulfill its data protection obligations under such written agreement with

Company, Company will remain liable to Customer for the performance of the Sub-Processor’s obligations under such

agreement.

4.3 If Customer and Company have entered into Standard Contractual Clauses as described in Section 6 (Transfers

of Personal Data), (i) the above authorizations will constitute Customer’s prior written consent to the subcontracting

by Company of the processing of Personal Data if such consent is required under the Standard Contractual Clauses,

and (ii) the parties agree that the copies of the agreements with Sub-Processors that must be provided by Company

to Customer pursuant to Clause 9(c) of the EU SCCs may have commercial information, or information unrelated to

the Standard Contractual Clauses or their equivalent, removed by the Company beforehand, and that such copies will

be provided by the Company only upon request by Customer.

5. Security of Personal Data.

Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of

processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons,

Company shall maintain appropriate technical and organizational measures to ensure a level of security appropriate

to the risk of processing Personal Data. Attachment C sets forth additional information about Company’s technical and

organizational security measures.

6. Transfers of Personal Data

6.1 The parties agree that Company may transfer Personal Data processed under this DPA outside the EEA, the

UK, or Switzerland as necessary to provide the Services. Customer acknowledges that though Company may process

Personal Data in other parts of the world in accordance with applicable Data Protection Laws, Company’s primary

processing operations take place in the United States, and that the transfer of Customer’s Personal Data to the United

States is necessary for the provision of the Services to Customer. If Company transfers Personal Data protected under

this DPA to a jurisdiction for which the European Commission has not issued an adequacy decision, Company will

ensure that appropriate safeguards have been implemented for the transfer of Personal Data in accordance with Data

Protection Laws.

6.2 Ex-EEA Transfers. The parties agree that ex-EEA Transfers are made pursuant to the EU SCCs, which are

deemed entered into (and incorporated into this DPA by this reference) and completed as follows:

6.2.1 Module One (Controller to Controller) of the EU SCCs apply when Company is processing Personal

Data as a controller pursuant to Section 9 of this DPA.

6.2.2 Module Two (Controller to Processor) of the EU SCCs apply when Customer is a controller and

Company is processing Personal Data for Customer as a processor pursuant to Section 2 of this DPA.

6.2.3 Module Three (Processor to Sub-Processor) of the EU SCCs apply when Customer is a processor and

Company is processing Personal Data on behalf of Customer as a sub-processor.

6.3 For each module, where applicable the following applies:

6.3.1 The optional docking clause in Clause 7 does not apply;

6.3.2 In Clause 9, Option 2 (general written authorization) applies;

6.3.3 In Clause 11, the optional language does not apply;

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6.3.4 All square brackets in Clause 13 are hereby removed;

6.3.5 In Clause 17 (Option 1), the EU SCCs will be governed by Ireland law;

6.3.6 In Clause 18(b), disputes will be resolved before the courts of Ireland;

6.3.7 Attachment B to this DPA contains the information required in Annex I and Annex III of the EU SCCs;

6.3.8 Attachment C to this DPA contains the information required in Annex II of the EU SCCs; and

6.3.9 By entering into this DPA, the parties are deemed to have signed the EU SCCs incorporated herein,

including their Annexes.

6.4 Ex-UK Transfers. The parties agree that ex-UK Transfers are made pursuant to the UK SCCs, which are deemed

entered into and incorporated into this DPA by reference, and amended and completed in accordance with the UK

Addendum, which is incorporated herein as Attachment D of this DPA.

6.5 Transfers from Switzerland. The parties agree that transfers from Switzerland are made pursuant to the EU

SCCs with the following modifications:

6.5.1 The terms “General Data Protection Regulation” or “Regulation (EU) 2016/679” as utilized in the EU

SCCs shall be interpreted to include the Federal Act on Data Protection of 19 June 1992 (the “FADP,”

and as revised as of 25 September 2020, the “Revised FADP”) with respect to data transfers subject

to the FADP.

6.5.2 The terms of the EU SCCs shall be interpreted to protect the data of legal entities until the effective

date of the Revised FADP.

6.5.3 Clause 13 of the EU SCCs is modified to provide that the Federal Data Protection and Information

Commissioner (“FDPIC”) of Switzerland shall have authority over data transfers governed by the

FADP and the appropriate EU supervisory authority shall have authority over data transfers governed

by the GDPR. Subject to the foregoing, all other requirements of Section 13 shall be observed.

6.5.4 The term “EU Member State” as utilized in the EU SCCs shall not be interpreted in such a way as to

exclude Data Subjects in Switzerland from exercising their rights in their place of habitual residence

in accordance with Clause 18(c) of the EU SCCs.

6.6 Supplementary Measures. In respect of any ex-EEA Transfer or ex-UK Transfer, the following supplementary

measures shall apply:

6.6.1 As of the date of this DPA, the Data Importer has not received any formal legal requests from any

government intelligence or security service/agencies in the country to which the Personal Data is

being exported, for access to (or for copies of) Customer’s Personal Data (“Government Agency

Requests”);

6.6.2 If, after the date of this DPA, the Data Importer receives any Government Agency Requests,

Company shall attempt to redirect the law enforcement or government agency to request that data

directly from Customer. As part of this effort, Company may provide Customer’s basic contact

information to the government agency. If compelled to disclose Customer’s Personal Data to a law

enforcement or government agency, Company shall give Customer reasonable notice of the demand

and cooperate to allow Customer to seek a protective order or other appropriate remedy unless

Company is legally prohibited from doing so. Company shall not voluntarily disclose Personal Data

to any law enforcement or government agency. Data Exporter and Data Importer shall (as soon as

reasonably practicable) discuss and determine whether all or any transfers of Personal Data

pursuant to this DPA should be suspended in the light of the such Government Agency Requests;

and

6.6.3 The Data Exporter and Data Importer will meet regularly to consider whether:

(i) the protection afforded by the laws of the country of the Data Importer to data subjects

whose Personal Data is being transferred is sufficient to provide broadly equivalent protection to

that afforded in the EEA or the UK, whichever the case may be;

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(ii) additional measures are reasonably necessary to enable the transfer to be compliant with

the Data Protection Laws; and

(iii) it is still appropriate for Personal Data to be transferred to the relevant Data Importer,

taking into account all relevant information available to the parties, together with guidance provided

by the supervisory authorities.

6.6.4 If Data Protection Laws require the Data Exporter to execute the Standard Contractual Clauses

applicable to a particular transfer of Personal Data to a Data Importer as a separate agreement, the

Data Importer shall, on request of the Data Exporter, promptly execute such Standard Contractual

Clauses incorporating such amendments as may reasonably be required by the Data Exporter to

reflect the applicable appendices and annexes, the details of the transfer and the requirements of

the relevant Data Protection Laws.

6.6.5 If either (i) any of the means of legitimizing transfers of Personal Data outside of the EEA or UK set

forth in this DPA cease to be valid or (ii) any supervisory authority requires transfers of Personal Data

pursuant to those means to be suspended, then Data Importer may by notice to the Data Exporter,

with effect from the date set out in such notice, amend or put in place alternative arrangements in

respect of such transfers, as required by Data Protection Laws.

6.7 Company and Customer agree that the data export solution identified in Sections 6.2 through 6.5 shall not

apply if and to the extent that Company adopts an alternative data export solution for the lawful transfer of Personal

Data, as recognized under applicable Data Protection Laws (“Alternative Transfer Mechanism”), in which event, the

Alternative Transfer Mechanism shall apply instead (but only to the extent such Alternative Transfer Mechanism

extends to the territories to which Personal Data is transferred).

7. Rights of Data Subjects

7.1 Company shall, to the extent permitted by law, notify Customer upon receipt of a request by a Data Subject

to exercise the Data Subject’s right of: access, rectification, erasure, data portability, restriction or cessation of

processing, withdrawal of consent to processing, and/or objection to being subject to processing that constitutes

automated decision-making (such requests individually and collectively “Data Subject Request(s)”). If Company

receives a Data Subject Request in relation to Customer’s data, Company will advise the Data Subject to submit their

request to Customer and Customer will be responsible for responding to such request, including, where necessary, by

using the functionality of the Services. Customer is solely responsible for ensuring that Data Subject Requests for

erasure, restriction or cessation of processing, or withdrawal of consent to processing of any Personal Data are

communicated to Company, and, if applicable, for ensuring that a record of consent to processing is maintained with

respect to each Data Subject.

7.2 Company shall, at the request of the Customer, and taking into account the nature of the processing

applicable to any Data Subject Request, apply appropriate technical and organizational measures to assist Customer

in complying with Customer’s obligation to respond to such Data Subject Request and/or in demonstrating such

compliance, where possible, provided that (i) Customer is itself unable to respond without Company’s assistance and

(ii) Company is able to do so in accordance with all applicable laws, rules, and regulations. Customer shall be

responsible to the extent legally permitted for any costs and expenses arising from any such assistance by Company.

8. Actions and Access Requests; Audits

8.1 Company shall, taking into account the nature of the processing and the information available to Company,

provide Customer with reasonable cooperation and assistance where necessary for Customer to comply with its

obligations under the GDPR to conduct a data protection impact assessment and/or to demonstrate such compliance,

provided that Customer does not otherwise have access to the relevant information. Customer shall be responsible to

the extent legally permitted for any costs and expenses arising from any such assistance by Company.

8.2 Company shall, taking into account the nature of the processing and the information available to Company,

provide Customer with reasonable cooperation and assistance with respect to Customer’s cooperation and/or prior

consultation with any Supervisory Authority, where necessary and where required by the GDPR. Customer shall be

responsible to the extent legally permitted for any costs and expenses arising from any such assistance by Company.

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8.3 Upon Customer’s written request at reasonable intervals, and subject to reasonable confidentiality controls,

Company shall, either (i) make available for Customer’s review copies of certifications or reports demonstrating

Company’s compliance with prevailing data security standards applicable to the processing of Customer’s Personal

Data, or (ii) if the provision of reports or certifications pursuant to (i) is not reasonably sufficient under Data Protection

Laws, allow Customer’s independent third party representative to conduct an audit or inspection of Company’s data

security infrastructure and procedures that is sufficient to demonstrate Company’s compliance with its obligations

under Data Protection Laws, provided that (a) Customer provides reasonable prior written notice of any such request

for an audit and such inspection shall not be unreasonably disruptive to Company’s business; (b) such audit shall only

be performed during business hours and occur no more than once per calendar year; and (c) such audit shall be

restricted to data relevant to Customer. Customer shall be responsible for the costs of any such audits or inspections,

including without limitation a reimbursement to Company for any time expended for on-site audits. If Customer and

Company have entered into Standard Contractual Clauses as described in Section 6 (Transfers of Personal Data), the

parties agree that the audits described in Clause 8.9 of the EU SCCs shall be carried out in accordance with this Section

8.4.

8.4 Company shall immediately notify Customer if an instruction, in the Company’s opinion, infringes the Data

Protection Laws or Supervisory Authority.

8.5 In the event of a Personal Data Breach, Company shall, without undue delay, inform Customer of the Personal

Data Breach and take such steps as Company in its sole discretion deems necessary and reasonable to remediate such

violation (to the extent that remediation is within Company’s reasonable control).

8.6 In the event of a Personal Data Breach, Company shall, taking into account the nature of the processing and

the information available to Company, provide Customer with reasonable cooperation and assistance necessary for

Customer to comply with its obligations under the GDPR with respect to notifying (i) the relevant Supervisory Authority

and (ii) Data Subjects affected by such Personal Data Breach without undue delay.

8.7 The obligations described in Sections 8.5 and 8.6 shall not apply in the event that a Personal Data Breach

results from the actions or omissions of Customer. Company’s obligation to report or respond to a Personal Data

Breach under Sections 8.4 and 8.5 will not be construed as an acknowledgement by Company of any fault or liability

with respect to the Personal Data Breach.

9. Company’s Role as a Controller. The parties acknowledge and agree that with respect to Company Account Data

and Company Usage Data, Company is an independent controller, not a joint controller with Customer. Company will

process Company Account Data and Company Usage Data as a controller (i) to manage the relationship with Customer;

(ii) to carry out Company’s core business operations, such as accounting, audits, tax preparation and filing and

compliance purposes; (iii) to monitor, investigate, prevent and detect fraud, security incidents and other misuse of the

Services, and to prevent harm to Customer; (iv) for identity verification purposes; (v) to comply with legal or regulatory

obligations applicable to the processing and retention of Personal Data to which Company is subject; and (vi) as

otherwise permitted under Data Protection Laws and in accordance with this DPA and the Agreement. Company may

also process Company Usage Data as a controller to provide, optimize, and maintain the Services, to the extent

permitted by Data Protection Laws. Any processing by the Company as a controller shall be in accordance with the

Company’s privacy policy set forth at https://www.risingwave.com/privacy-policy/.

10. Conflict. In the event of any conflict or inconsistency among the following documents, the order of precedence

will be: (1) the applicable terms in the Standard Contractual Clauses; (2) the terms of this DPA; (3) the Agreement; and

(4) the Company’s privacy policy. Company’s failure to comply with any of the provisions of this DPA is a material

breach of the underlying Agreement. In such event, Customer may terminate the Agreement effective immediately

upon written notice to Company without further liability or obligation to Company.

11. Execution of this DPA. To complete this DPA, Customer must: (i) complete the information requested in the

signature block below and sign there, (ii) complete the information requested of the “data exporter” on Attachment

B, and (iii) send the completed and signed Addendum to Company by email to contact@risingwave-labs.com. Upon

receipt of the validly completed DPA by Company at this email address, this DPA will become legally binding.

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Customer

RisingWave

Signature:

Customer Legal Name:

Signature:

Print Name:

Title:

Date:

Attachment A

Details of Processing

Nature and Purpose of Processing: Company will process Customer’s Personal Data as necessary to provide the

Services under the Agreement, for the purposes specified in the Agreement and this DPA, and in accordance with

Customer’s instructions as set forth in this DPA. The nature of processing includes, without limitation:

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Receiving data, including collection, accessing, retrieval, recording, and data entry

Holding data, including storage, organization and structuring

Using data, including analysis, testing, support

Protecting data, including restricting, encrypting, and security testing

Sharing data, including disclosure, dissemination, allowing access or otherwise making available

Returning data to the data exporter or data subject

Erasing data, including destruction and deletion

Duration of Processing: Company will process Customer’s Personal Data as long as required (i) to provide the

Services to Customer under the Agreement; (ii) for Company’s legitimate business needs; or (iii) by applicable law or

regulation. Company Account Data and Company Usage Data will be processed and stored as set forth in Company’s

Categories of Data Subjects: Any individual accessing and/or using the Services through the Customer's account

("Users"); and any individual whose information is stored on or collected via the Services.

Categories of Personal Data: Company processes Personal Data contained in Company Account Data, Company

Usage Data, and any Personal Data provided by Customer (including any Personal Data Customer collects from its

end users and processes through its use of the Services) or collected by Company in order to provide the Services or

as otherwise set forth in the Agreement or this DPA. Categories of Personal Data include identification and contact

data (name, address, title, contact details, username); financial information (credit card details, account details,

payment information); employment details (employer, job title, geographic location, area of responsibility) or any

additional Personal Data provided by Customer.

Sensitive Data or Special Categories of Data: None.

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Attachment B

The following includes the information required by Annex I and Annex III of the EU SCCs, and Appendix 1 of the UK

SCCs.

1. The Parties

Data exporter(s): [Identity and contact details of the data exporter(s) and, where applicable, of its/their data

protection officer and/or representative in the European Union]

Name:

Trading Name (if different):

Address:

Official Registration Number (if any) (company number or similar identifier):

Contact person’s name, position and contact details:

Activities relevant to the data transferred under these Clauses:

Signature and date:

Role (controller/processor):

Data importer(s): Identity and contact details of the data importer(s), including any contact person with

responsibility for data protection

Name: SINGULARITY DATA LIMITED, A DELAWARE CORPORATION, DBA RISINGWAVE LABS

Address: 95 3RD ST, 2ND FLOOR, SAN FRANCISCO, CA 94103

Contact Person Name, Position and Contact Details: Rayees Pasha; Head of Product; e-mail: contact@risingwave-

labs.com

Signature and date:

Role (controller/processor): As described in Section 2

2. Description of the Transfer

Data Subjects