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Last updated: June 7, 2021
This Data Processing Addendum ("DPA") outlines the terms to which customer personal data is processed by GemPages (“GemPages”, “us”, or “we”) in compliance with Global Data Protection Legislation. In this agreement “you”, “your” and “Customer” refers to you unless otherwise indicated. If you are entering into this agreement on behalf of a company or other legal entities, you represent that you have the authority to bind such an entity to this agreement, in which case the terms “you” or “your” shall refer to such entity.
For purposes of this Addendum, terms will have the meanings set forth below. Capitalized terms that are used but not otherwise defined in this Addendum shall have the meanings set forth in the Agreement.
“Addendum Effective Date” means the date on which the parties involved agreed to this Addendum.
“Affiliate” means any entity that directly or indirectly controls, is controlled by or is under common control with the subject entity, where “control” refers to the power to direct or cause the direction of the subject entity, whether through ownership of voting securities, by contract or otherwise.
“Customer Personal Data” means any personal data and personal information of data subjects contained within the data provided to or accessed by GemPages by or on behalf of Customer in connection with the Services.
“Data Subjects” meaning individuals, organizations and etc. of whom’s data is collected, processed, shared, by the Customer.
“Global Data Protection Legislation” means the European Data Protection Legislation, CCPA, and LGPD as applicable to the processing of Customer Personal Data under the Agreement.
“European Data Protection Legislation” means the GDPR and other data protection laws of the EU, its Member States, Switzerland, Iceland, Liechtenstein and Norway, and the United Kingdom, applicable to the processing of Customer Personal Data under the Agreement.
“GDPR” means 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 of EU data subjects and on the free movement of such data, and repealing Directive 95/46/EC.
“Security Measures” has the meaning given in Section 5 (GemPages’ Security Measures).
“Services” means the services and/or products provided by GemPages to Customers.
“Sub Processors” means third parties authorized under this Addendum to process Customer Personal Data in relation to the Services.
The terms “personal data”, “data subject”, “processing”, “controller”, “processor” and “supervisory authority” as used in this Addendum have the meanings given in the GDPR and Global Data Protection Legislation, as applicable, and the terms “data importer” and “data exporter” have the meanings given in the Standard Contractual Clauses. The terms “personal information”, “Business”, and “Service Provider” have the meanings set forth in the CCPA.
This Addendum will take effect on the Addendum Effective Date and, notwithstanding the expiration of the Term, will remain in effect until and automatically expire upon GemPages's deletion of all Customer Personal Data as described in this Addendum.
1. Roles and Regulatory Compliance; Authorization
Customers can use the Services to process Personal Information of their customers or contacts for marketing and related customer relationship management purposes. GemPages stores Personal Information on its servers and processes such Personal Information only for the purposes of, and in accordance with, the instructions of Customers and does not make any decisions itself as to the use, updating, or deletion of Personal Information. If the Global Data Processing Legislation applies to the processing of Customer Personal Data, the parties acknowledge and agree that:
The subject matter and details of the processing are described in Annex 1.
GemPages is a processor and or Service Provider of Customer Personal Data under the Global Data Protection Legislation.
The Customer is either a controller or processor of that Customer or a Business with respect to Global Data Protection Legislation.
Each party will comply with the obligations applicable to it under the applicable Global Data Protection Legislation with respect to the processing of that Customer Personal Data.
2. Scope of Processing
By entering into this Addendum, Customer instructs GemPages to process Customer Personal Data only in accordance with applicable law to provide the Services as authorized by the Agreement, including this Addendum and its Appendices or as further documented in any other written instructions given by Customer and acknowledged in writing by GemPages as constituting instructions for purposes of this Addendum.
GemPages will only process Customer Personal Data in accordance with customer’s instructions unless the applicable personal data to which we are subject requires us to further process Customer Personal Data, in which case GemPages will notify Customer (unless that law prohibits us from doing so on grounds of public interest).
If the Global Data Protection Legislation applies to the processing of Customer Personal Data, the Customer is a processor and notify GemPages of their instructions and actions regarding Customer Personal Data, including its appointment of GemPages as another processor or its consent to GemPages’s onward transfers of Customer Personal Data to its Subprocessors.
Data is deleted or returned upon termination of the Agreement. GemPages shall delete or return to Customer(s) all Customer Data (including copies) in its possession or control, except that this requirement shall not apply to the extent we are required by the applicable law to retain some or all of the Customer Data, or to Customer Data it has archived on back-up systems. In which Customer Data shall securely isolate, protect from any further processing, and eventually delete in accordance with our Data Retention Policy.
1. Security Measures
GemPages shall implement and maintain appropriate technical and organizational security measures to protect Company Data from Security Incidents and to preserve the security and confidentiality of the Company Data, in accordance with GemPages’ security standards described in Appendix 2.
2. Updates to Security Measures
You acknowledge that the Security Measures are subject to technical progress and development and that GemPages may update or modify the Security Measures from time to time provided that such updates and modifications do not result in the degradation of the overall security of the Services.
3. Confidentiality of Processing
GemPages shall ensure that any person who is authorized by you to process Personal Data (including its staff, agents, and subcontractors) shall be under an appropriate obligation of confidentiality (whether a contractual or statutory duty).
4. Security Incident Response
Upon becoming aware of an Information Security Incident, GemPages shall notify Customers without undue delay and shall provide timely information relating to the Security Incident as it becomes known or as is reasonably requested by you.
5. Company Responsibilities
Notwithstanding the above, you agree that except as provided by this DPA, you are responsible for safeguarding and securing your use of our Services, including securing its account authentication credentials, protecting the security of your Personal Information Data when in transit to and from the Services, and taking any appropriate steps to securely encrypt or backup any Customer Generated Data Customer Personal Uploaded to the Services.
1. Customer’s Responsibility for Requests
During the Agreement, if GemPages receives any request from a Data Subject in relation to Customer Personal Data, GemPages will, at its sole discretion, (i) advise the Customer of the request, (ii) advise the data subject to submit his or her request to Customer, and/or (iii) notify the data subject that his or her request has been forwarded to the Customer. Customers will be responsible for responding to any such request.
2. GemPages’ Data Subject Request Assistance
GemPages will (taking into account the nature of the processing of Customer Personal Data) provide Customer with self-service functionality through the Services or other reasonable assistance as necessary for Customer to fulfill its obligation under the applicable Global Data Protection Legislation to respond to requests by Data Subject(s), including if applicable, Customer’s obligation to respond to requests for exercising the data subject’s rights set out in Global Data Processing Legislation. Customer shall reimburse GemPages for any such assistance beyond providing self-service features included as part of the Services at GemPages’ then-current professional services rates, which shall be made available to Customer upon request.
GemPages will reasonably assist Customer in complying with its obligations under the applicable Global Data Protection Legislation in respect of data protection impact assessments and prior consultation, including, if applicable, Customer’s obligations pursuant to Articles 35 and 36 of the GDPR, by:
Security Measures: Making available documentation describing relevant aspects of GemPages’ information security program and the security measures applied in connection therewith.
Additional Information: Providing the information contained in the Agreement including this Addendum.
Where required by Applicable Law, we will use commercially reasonable efforts not to transfer any Personal Information from one country to another without Customers’ prior written consent, which Customers shall not unreasonably withhold, and which Customers hereby provides as required for our provision of Services under the Agreement. Where Customers consent to such transfer, the transfer will be in accordance with applicable law.
1. Datacenter locations
GemPages may transfer and process Personal Information Data anywhere in the world where GemPages, its Affiliates, or its Sub Processes maintain data Processing operations. GemPages shall at all times provide an adequate level of protection for the Personal Information Data collected, transferred, processed, or retained in accordance with the requirements of the applicable Global Data Processing Legislation.
2. Transfer Mechanism
The parties will comply with the applicable Global Data Protection Law and use the appropriate data transfer mechanism to transfer or access Personal Information internationally. GemPages makes available SCCs enable transfers of Personal Information from the US to other jurisdictions. Customers can exercise their rights and submit a request to enquire about acquired personal information and data under the GDPR by referring to https://gmpg.link/gdpr
1. Authorized Sub-processors
GemPages uses sub-processors to carry out processing activities that are essential to providing quality user experiences. A sub-processor is a third-party data processor who agrees to receive personal information data from GemPages intended for processing activities to be carried out (i) on behalf of GemPages customers; (ii) and in accordance with customer instructions as communicated by GemPages.
GemPages uses the following sub-processors for customer data:
Amazon Web Services, Inc.
Behavior, Customer Support, File Storage
Peaberry Software, Inc.
Slack Technologies, Inc.
Mango Technologies, Inc.
We may update this list from time to time for operational, legal, or other reasons. Please revisit this list regularly to stay informed.
The date at the top of this addendum indicates when it was last updated.
2. Sub-processor obligations
GemPages shall enter into a written agreement with each Sub-processor containing data protection obligations that provide at least the same level of protection for Customer Data as those in this DPA, to the extent applicable to the nature of the service provided by such Sub-processor. However, GemPages is not responsible for Sub-processor's compliance with the obligations of this DPA and for any acts or omissions of such Sub-processor that cause us to breach any of its obligations under this DPA.
Customer acknowledges that GemPages is required under the GDPR to (a) collect and maintain records of certain information, including the name and contact details of each processor and/or controller on behalf of which GemPages is acting and, where applicable, of such processor’s or controller's local representative and data protection officer; and (b) make such information available to the supervisory authorities. Accordingly, if the GDPR applies to the processing of Customer Personal Data, Customer will, where requested, provide such information to GemPages, and will ensure that all information provided is kept accurate and up-to-date.
Each party and all of its Affiliates’ liability arising out whether in contract, tort, or any other theory of liability, under or in connection with this Addendum, and other Policies shall be subject to the exclusions and limitations of liability set forth in the Agreement. Any claims made against GemPages or its Affiliates under or in connection shall be brought solely by the Customer entity that is a party to the Agreement.
Customer acknowledges and agrees that GemPages may create and derive anonymized and/or aggregated data that does not identify Customer or any natural person from processing related to the Services to use, publicize or share with third parties such data to improve GemPages’ products and services and for its other legitimate business purposes.
Notwithstanding anything to the contrary in the Agreement, any notices required or permitted to be given by GemPages to Customer may be given (a) to GemPages’ primary points of contact with Customer; and/or (b) to any email provided by Customer for the purpose of providing it with Service-related communications or alerts. Customer is solely responsible for ensuring that such email addresses are valid.
Notwithstanding anything to the contrary in the Agreement, to the extent of any conflict or inconsistency between this Addendum and the remaining terms of the Agreement, this Addendum will govern.
If you have any questions, please email us at email@example.com or by post to:
Seal Commerce Asia
16th Floor, TNR Tower, 54A Nguyen Chi Thanh Str
Dong Da Dist, Hanoi, Vietnam.
GemPages shall provide the Customer information according to the Agreement and the DPA. GemPages shall process information sent by Customers’ end users identified through Customers’ implementation of the Application Services.
Types of Personal Data
Depending on Customer’s usage of the Service, this could include the data exporter’s personnel, as well as individuals in other categories, such as the data exporter’s customers, service providers, business partners, affiliates, and other end users.
Because we are an Official Shopify App Developer, please refer to the full list of Customer properties from Shopify API.
Categories of Data Subjects
The Service does not impose a technical restriction on the categories of Personal Information Data Customer may provide as it varies widely from end-users, referrals, to affiliates, and so on.
Special categories of data (if appropriate)
The Service does not impose a technical restriction on the categories of Personal Information Data Customer may provide.
The subject matter, nature, and purpose of the processing are GemPages’ provision of the Service to Customer as further described in the Agreement.
This involves storing Personal Data, making it available to Customer for modification and transmission, and deleting Personal Data. The processing takes place from the commencement of the Agreement until the deletion of all Personal Data by GemPages in accordance with the DPA.
For the purposes of Article 26(2) of Directive 95/46/EC for the transfer of personal data to processors established in third countries which do not ensure an adequate level of data protection.
The Parties (Customer as Data Exporter and GemPages as Data Importer):
HAVE AGREED on the following Contractual Clauses (the Clauses) in order to adduce adequate safeguards with respect to the protection of privacy and fundamental rights and freedoms of individuals for the transfer by the Data Exporter to the Data Importer of the Personal Data identified in either the Agreement or Annex 1 to the DPA.
For the purposes of the Clauses:
(a) ‘personal data’, ‘special categories of data’, ‘process/processing’, ‘controller’, ‘processor’, ‘data subject’ and ‘supervisory authority’ shall have the same meaning as in Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 on the protection of individuals with regard to the processing of personal data and on the free movement of such data;
(b) ‘the data exporter’ means the controller who transfers the personal data;
(c) ‘the data importer’ means the processor, identified above, who agrees to receive from the data exporter personal data intended for processing on his behalf after the transfer in accordance with his instructions and the terms of the Clauses and who is not subject to a third country’s system ensuring adequate protection within the meaning of Article 25(1) of Directive 95/46/EC;
(d) ‘the sub-processor’ means any processor engaged by the data importer or by any other sub-processor of the data importer who agrees to receive from the data importer or from any other sub-processor of the data importer personal data exclusively intended for processing activities to be carried out on behalf of the data exporter after the transfer in accordance with his instructions, the terms of the Clauses and the terms of the written subcontract;
(e) ‘the applicable data protection law’ means the legislation protecting the fundamental rights and freedoms of individuals and, in particular, their right to privacy with respect to the processing of personal data applicable to a data controller in the Member State in which the data exporter is established;
(f) ‘technical and organizational security measures’ means those measures aimed at protecting personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access, in particular where the processing involves the transmission of data over a network, and against all other unlawful forms of processing.
Details of the transfer
The details of the transfer and in particular the special categories of personal data where applicable are specified in Appendix 1 which forms an integral part of the Clauses.
Third-party beneficiary clause
The data subject can enforce against the data exporter this Clause, Clause 4(b) to (i), Clause 5(a) to (e), and (g) to (j), Clause 6(1) and (2), Clause 7, Clause 8(2), and Clauses 9 to 12 as a third-party beneficiary.
The data subject can enforce against the data importer this Clause, Clause 5(a) to (e) and (g), Clause 6, Clause 7, Clause 8(2), and Clauses 9 to 12, in cases where the data exporter has factually disappeared or has ceased to exist in law unless any successor entity has assumed the entire legal obligations of the data exporter by contract or by operation of law, as a result of which it takes on the rights and obligations of the data exporter, in which case the data subject can enforce them against such entity.
The data subject can enforce against the sub-processor this Clause, Clause 5(a) to (e) and (g), Clause 6, Clause 7, Clause 8(2), and Clauses 9 to 12, in cases where both the data exporter and the data importer have factually disappeared or ceased to exist in law or have become insolvent unless any successor entity has assumed the entire legal obligations of the data exporter by contract or by operation of law as a result of which it takes on the rights and obligations of the data exporter, in which case the data subject can enforce them against such entity. Such third-party liability of the sub-processor shall be limited to its own processing operations under the Clauses.
The Parties do not object to a data subject being represented by an association or other body if the data subject so expressly wishes and if permitted by national law.
Obligations of the data exporter
The data exporter agrees and warrants:
(a) that the processing, including the transfer itself, of the personal data, has been and will continue to be carried out in accordance with the relevant provisions of the applicable data protection law (and, where applicable, has been notified to the relevant authorities of the Member State where the data exporter is established) and does not violate the relevant provisions of that State;
(b) that it has instructed and throughout the duration of the personal data processing services will instruct the data importer to process the personal data transferred only on the data exporter’s behalf and in accordance with the applicable data protection law and the Clauses;
(c) that the data importer will provide sufficient guarantees in respect of the technical and organizational security measures specified in Appendix 2 to this contract;
(d) that after assessment of the requirements of the applicable data protection law, the security measures are appropriate to protect personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access, in particular where the processing involves the transmission of data over a network, and against all other unlawful forms of processing, and that these measures ensure a level of security appropriate to the risks presented by the processing and the nature of the data to be protected having regard to the state of the art and the cost of their implementation;
(e) that it will ensure compliance with the security measures;
(f) that, if the transfer involves special categories of data, the data subject has been informed or will be informed before, or as soon as possible after, the transfer that its data could be transmitted to a third country not providing adequate protection within the meaning of Directive 95/46/EC;
(g) to forward any notification received from the data importer or any sub-processor pursuant to Clause 5(b) and Clause 8(3) to the data protection supervisory authority if the data exporter decides to continue the transfer or to lift the suspension;
(h) to make available to the data subjects upon request a copy of the Clauses, with the exception of Appendix 2, and a summary description of the security measures, as well as a copy of any contract for sub-processing services which has to be made in accordance with the Clauses, unless the Clauses or the contract contain commercial information, in which case it may remove such commercial information;
(i) that, in the event of sub-processing, the processing activity is carried out in accordance with Clause 11 by a sub-processor providing at least the same level of protection for the personal data and the rights of data subject as the data importer under the Clauses; and
(j) that it will ensure compliance with Clause 4(a) to (i).
Obligations of the data importer
(a) to process the personal data only on behalf of the data exporter and in compliance with its instructions and the Clauses; if it cannot provide such compliance for whatever reasons, it agrees to inform promptly the data exporter of its inability to comply, in which case the data exporter is entitled to suspend the transfer of data and/or terminate the contract;
(b) that it has no reason to believe that the legislation applicable to it prevents it from fulfilling the instructions received from the data exporter and its obligations under the contract and that in the event of a change in this legislation which is likely to have a substantial adverse effect on the warranties and obligations provided by the Clauses, it will promptly notify the change to the data exporter as soon as it is aware, in which case the data exporter is entitled to suspend the transfer of data and/or terminate the contract;
(c) that it has implemented the technical and organisational security measures specified in Appendix 2 before processing the personal data transferred;
(d) that it will promptly notify the data exporter about:
i. any legally binding request for disclosure of the personal data by a law enforcement authority unless otherwise prohibited, such as a prohibition under criminal law to preserve the confidentiality of a law enforcement investigation;
ii. any accidental or unauthorized access; and
iii. any request received directly from the data subjects without responding to that request, unless it has been otherwise authorized to do so;
(e) to deal promptly and properly with all inquiries from the data exporter relating to its processing of the personal data subject to the transfer and to abide by the advice of the supervisory authority with regard to the processing of the data transferred;
(f) at the request of the data exporter to submit its data processing facilities for audit of the processing activities covered by the Clauses which shall be carried out by the data exporter or an inspection body composed of independent members and in possession of the required professional qualifications bound by a duty of confidentiality, selected by the data exporter, where applicable, in agreement with the supervisory authority;
(g) to make available to the data subject upon request a copy of the Clauses, or any existing contract for sub-processing, unless the Clauses or contract contain commercial information, in which case it may remove such commercial information, with the exception of Appendix 2 which shall be replaced by a summary description of the security measures in those cases where the data subject is unable to obtain a copy from the data exporter;
(h) that, in the event of sub-processing, it has previously informed the data exporter and obtained its prior written consent;
(i) that the processing services by the sub-processor will be carried out in accordance with Clause 11;
(j) to send promptly a copy of any sub-processor agreement it concludes under the Clauses to the data exporter.
1. The Parties agree that any data subject, who has suffered damage as a result of any breach of the obligations referred to in Clause 3 or in Clause 11 by any party or sub-processor is entitled to receive compensation from the data exporter for the damage suffered.
2. If a data subject is not able to bring a claim for compensation in accordance with paragraph 1 against the data exporter, arising out of a breach by the data importer or his sub-processor of any of their obligations referred to in Clause 3 or in Clause 11, because the data exporter has factually disappeared or ceased to exist in law or has become insolvent, the data importer agrees that the data subject may issue a claim against the data importer as if it were the data exporter, unless any successor entity has assumed the entire legal obligations of the data exporter by contract of by operation of law, in which case the data subject can enforce its rights against such entity.
The data importer may not rely on a breach by a sub-processor of its obligations in order to avoid its own liabilities.
3. If a data subject is not able to bring a claim against the data exporter or the data importer referred to in paragraphs 1 and 2, arising out of a breach by the sub-processor of any of their obligations referred to in Clause 3 or in Clause 11 because both the data exporter and the data importer have factually disappeared or ceased to exist in law or have become insolvent, the sub-processor agrees that the data subject may issue a claim against the data sub-processor with regard to its own processing operations under the Clauses as if it were the data exporter or the data importer, unless any successor entity has assumed the entire legal obligations of the data exporter or data importer by contract or by operation of law, in which case the data subject can enforce its rights against such entity. The liability of the sub-processor shall be limited to its own processing operations under the Clauses.
Mediation and jurisdiction
1. The data importer agrees that if the data subject invokes against it third-party beneficiary rights and/or claims compensation for damages under the Clauses, the data importer will accept the decision of the data subject:
a. to refer the dispute to mediation, by an independent person or, where applicable, by the supervisory authority;
b. to refer the dispute to the courts in the Member State in which the data exporter is established.
2. The Parties agree that the choice made by the data subject will not prejudice its substantive or procedural rights to seek remedies in accordance with other provisions of national or international law.
Cooperation with supervisory authorities
1. The data exporter agrees to deposit a copy of this contract with the supervisory authority if it so requests or if such deposit is required under the applicable data protection law.
2. The Parties agree that the supervisory authority has the right to conduct an audit of the data importer, and of any sub-processor, which has the same scope and is subject to the same conditions as would apply to an audit of the data exporter under the applicable data protection law.
3. The data importer shall promptly inform the data exporter about the existence of legislation applicable to it or any sub-processor preventing the conduct of an audit of the data importer, or any sub-processor, pursuant to paragraph 2. In such a case the data exporter shall be entitled to take the measures foreseen in Clause 5 (b).
The Clauses shall be governed by the law of the Member State in which the data exporter is established.
Variation of the contract
The Clauses shall be governed by the law of the Member State in which the data exporter is established.
Cooperation with supervisory authoritiesSub-processing
1. The data importer shall not subcontract any of its processing operations performed on behalf of the data exporter under the Clauses without the prior written consent of the data exporter. Where the data importer subcontracts its obligations under the Clauses, with the consent of the data exporter, it shall do so only by way of a written agreement with the sub-processor which imposes the same obligations on the sub-processor as are imposed on the data importer under the Clauses. Where the sub-processor fails to fulfill its data protection obligations under such written agreement the data importer shall remain fully liable to the data exporter for the performance of the sub-processor’s obligations under such agreement.
2. The prior written contract between the data importer and the sub-processor shall also provide for a third-party beneficiary clause as laid down in Clause 3 for cases where the data subject is not able to bring the claim for compensation referred to in paragraph 1 of Clause 6 against the data exporter or the data importer because they have factually disappeared or have ceased to exist in law or have become insolvent and no successor entity has assumed the entire legal obligations of the data exporter or data importer by contract or by operation of law. Such third-party liability of the sub-processor shall be limited to its own processing operations under the Clauses.
3. The provisions relating to data protection aspects for sub-processing of the contract referred to in paragraph 1 shall be governed by the law of the Member State in which the data exporter is established.
4. The data exporter shall keep a list of sub-processing agreements concluded under the Clauses and notified by the data importer pursuant to Clause 5 (j), which shall be updated at least once a year. The list shall be available to the data exporter’s data protection supervisory authority.
Obligation after termination of personal data processing services
1. The Parties agree that on the termination of the provision of data processing services, the data importer and the sub-processor shall, at the choice of the data exporter, return all the personal data transferred and the copies thereof to the data exporter or shall destroy all the personal data and certify to the data exporter that it has done so, unless legislation imposed upon the data importer prevents it from returning or destroying all or part of the personal data transferred. In that case, the data importer warrants that it will guarantee the confidentiality of the personal data transferred and will not actively process the personal data transferred anymore.
2. The data importer and the sub-processor warrant that upon request of the data exporter and/or of the supervisory authority, it will submit its data processing facilities for an audit of the measures referred to in paragraph 1.
The data exporter is the entity identified as “Customer” or “Controller” in the Agreement.
The data importer is Seal Commerce, Inc. (“GemPages”), a company providing hosted business software applications that processes personal data upon the instruction of the data exporter in accordance with the terms of the Agreement.
The personal data transferred concerns the categories of data subjects defined in Annex 1 to the DPA.
Categories of data
The personal data transferred concerns the categories of data defined in Annex 1 to the DPA.
Special categories of data (if appropriate)
The personal data transferred concerns the special categories of data defined in Annex 1 to the DPA.
The personal data transferred will be subject to the basic processing activities defined in Annex 1 to the DPA.
This Appendix 2 is incorporated into the Addendum, and also forms part of the Standard Contractual Clauses (if such Standard Contractual Clauses are applicable to Customer).
As from the Addendum Effective Date, GemPages will implement and maintain the technical and organizational Security Measures set out at (under construction).