Data Processing Agreement

This Tightknit Data Processing Agreement and its Annexes ("DPA") reflect the parties' agreement with respect to the Processing of Personal Data by us on behalf of you in connection with the Tightknit Subscription Services under the Tightknit Sales Agreement (comprising the Order Form and Terms and Conditions) between you and us (also referred to in this DPA as the "Agreement").

This DPA is supplemental to, and forms an integral part of, the Agreement and is effective upon its incorporation into the Agreement, which may be specified in the Agreement, an Order Form or an executed amendment to the Agreement. In case of any conflict or inconsistency with the terms of the Agreement, this DPA will take precedence over the terms of the Agreement to the extent of such conflict or inconsistency.

We update these terms from time to time. If you have an active Tightknit subscription, we will let you know when we do via email, our Slack community, or our Slack application. The term of this DPA will follow the term of the Agreement. Terms not otherwise defined in this DPA will have the meaning as set forth in the Agreement. Should any such updates or changes to this DPA materially reduce your rights or increase your obligations, you have the right to terminate the affected Subscription Service in accordance with the termination provisions of the Agreement, without liability to either party, provided such termination right is exercised within thirty (30) days of receiving notification of the changes.

1. Definitions

"California Personal Information" means Personal Data that is subject to the protection of the CCPA.

"CCPA" means California Civil Code Sec. 1798.100 et seq. (also known as the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 or "CPRA").

"Consumer", "Business", "Sell", "Service Provider", and "Share" will have the meanings given to them in the CCPA.

"Controller" means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the Processing of Personal Data.

"Data Privacy Framework" means the EU-U.S. Data Privacy Framework, the Swiss-U.S. Data Privacy Framework and the UK Extension to the EU-U.S. Data Privacy Framework self-certification programs (as applicable) operated by the U.S. Department of Commerce; as may be amended, superseded or replaced.

"Data Privacy Framework Principles" means the Principles and Supplemental Principles contained in the relevant Data Privacy Framework; as may be amended, superseded or replaced.

"Data Protection Laws" means all applicable worldwide legislation relating to data protection and privacy which applies to the respective party in the role of Processing Personal Data in question under the Agreement, including without limitation European Data Protection Laws, the CCPA and other applicable U.S. federal and state privacy laws, and the data protection and privacy laws of Australia, Singapore, and Japan, in each case as amended, repealed, consolidated or replaced from time to time.

"Data Subject" means the individual to whom Personal Data relates.

"Europe" means the European Union, the European Economic Area and/or their member states, Switzerland and the United Kingdom.

"European Data" means Personal Data that is subject to the protection of European Data Protection Laws.

"European Data Protection Laws" means data protection laws applicable in Europe, including: (i) Regulation 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation) ("GDPR"); (ii) Directive 2002/58/EC concerning the processing of personal data and the protection of privacy in the electronic communications sector; and (iii) applicable national implementations of (i) and (ii); or (iii) GDPR as it forms part of the United Kingdom domestic law by virtue of Section 3 of the European Union (Withdrawal) Act 2018 ("UK GDPR"); and (iv) Swiss Federal Data Protection Act and its Ordinance ("Swiss DPA"); in each case, as may be amended, superseded or replaced.

"Instructions" means the written, documented instructions issued by a Controller to a Processor, and directing the same to perform a specific or general action with regard to Personal Data (including, but not limited to, depersonalizing, blocking, deletion, making available).

"Permitted Affiliates" means any of your Affiliates that (i) are permitted to use the Subscription Services pursuant to the Agreement, but have not signed their own separate agreement with us and are not a "Customer" as defined under the Agreement, (ii) qualify as a Controller of Personal Data Processed by us, and (iii) are subject to European Data Protection Laws.

"Personal Data" means any information relating to an identified or identifiable individual where (i) such information is contained within Customer Data; and (ii) is protected similarly as personal data, personal information or personally identifiable information under applicable Data Protection Laws.

"Personal Data Breach" means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Data transmitted, stored or otherwise Processed by us and/or our Sub-Processors in connection with the provision of the Subscription Services. "Personal Data Breach" will not include unsuccessful attempts or activities that do not compromise the security of Personal Data, including unsuccessful log-in attempts, pings, port scans, denial of service attacks, and other network attacks on firewalls or networked systems.

"Processing" means any operation or set of operations which is performed on Personal Data, encompassing the collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction or erasure of Personal Data. The terms "Process", "Processes" and "Processed" will be construed accordingly.

"Processor" means a natural or legal person, public authority, agency or other body which Processes Personal Data on behalf of the Controller.

"Standard Contractual Clauses" means the standard contractual clauses annexed to the European Commission's Decision (EU) 2021/914 of 4 June 2021, as may be amended, superseded or replaced.

"Sub-Processor" means any Processor engaged by us or our Affiliates to assist in fulfilling our obligations with respect to the provision of the Subscription Services under the Agreement. Sub-Processors may include third parties or our Affiliates but will exclude any Tightknit employee or consultant.

"UK Addendum" means the International Data Transfer Addendum issued by the UK Information Commissioner under section 119A(1) of the Data Protection Act 2018, as may be amended, superseded, or replaced.

2. Customer Responsibilities

Compliance with Laws. Within the scope of the Agreement and in its use of the services, you will be responsible for complying with all requirements that apply to it under applicable Data Protection Laws with respect to its Processing of Personal Data and the Instructions it issues to us. In particular but without prejudice to the generality of the foregoing, you acknowledge and agree that you will be solely responsible for: (i) the accuracy, quality, and legality of Customer Data and the means by which you acquired Personal Data; (ii) complying with all necessary transparency and lawfulness requirements under applicable Data Protection Laws for the collection and use of the Personal Data, including obtaining any necessary consents and authorizations (particularly for use by Customer for marketing purposes); (iii) ensuring you have the right to transfer, or provide access to, the Personal Data to us for Processing in accordance with the terms of the Agreement (including this DPA); (iv) ensuring that your Instructions to us regarding the Processing of Personal Data comply with applicable laws, including Data Protection Laws; and (v) complying with all laws (including Data Protection Laws) applicable to any emails or other content created, sent or managed through the Subscription Services, including those relating to obtaining consents (where required) to send emails, the content of the emails and its email deployment practices. You will inform us without undue delay if you are not able to comply with your responsibilities under this section or applicable Data Protection Laws.

Controller Instructions. The parties agree that the Agreement (including this DPA), together with your use of the Subscription Service in accordance with the Agreement, constitute your complete Instructions to us in relation to the Processing of Personal Data, so long as you may provide additional instructions during the subscription term that are consistent with the Agreement, the nature and lawful use of the Subscription Service.

Security. You are responsible for independently determining whether the data security provided for in the Subscription Service adequately meets your obligations under applicable Data Protection Laws. You are also responsible for your secure use of the Subscription Service, including protecting the security of Personal Data in transit to and from the Subscription Service (including to securely backup or encrypt any such Personal Data).

3. Tightknit Obligations

Compliance with Instructions. We will only Process Personal Data for the purposes described in this DPA or as otherwise agreed within the scope of your lawful Instructions, except where and to the extent otherwise required by applicable law. We are not responsible for compliance with any Data Protection Laws applicable to you or your industry that are not generally applicable to us.

Conflict of Laws. If we become aware that we cannot Process Personal Data in accordance with your Instructions due to a legal requirement under any applicable law, we will (i) promptly notify you of that legal requirement to the extent permitted by the applicable law; and (ii) where necessary, cease all Processing (other than merely storing and maintaining the security of the affected Personal Data) until such time as you issue new Instructions with which we are able to comply. If this provision is invoked, we will not be liable to you under the Agreement for any failure to perform the applicable Subscription Services until such time as you issue new lawful Instructions with regard to the Processing.

Security. We will implement and maintain appropriate technical and organizational measures to protect Personal Data from Personal Data Breaches, as described under Annex 2 to this DPA ("Security Measures"). Notwithstanding any provision to the contrary, we may modify or update the Security Measures at our discretion provided that such modification or update does not result in a material degradation in the protection offered by the Security Measures.

Confidentiality. We will ensure that any personnel whom we authorize to Process Personal Data on our behalf is subject to appropriate confidentiality obligations (whether a contractual or statutory duty) with respect to that Personal Data.

Personal Data Breaches. We will notify you without undue delay, and in any case within forty-eight (48) hours, after we become aware of any Personal Data Breach. That notification will include, to the extent then known, a contact point from whom further information can be obtained, a description of the nature of the breach, its likely consequences, and the measures taken or proposed to address it, and we will provide further information relating to the Personal Data Breach as it becomes known or is reasonably requested by you. At your request, we will promptly provide you with such reasonable assistance as necessary to enable you to notify relevant Personal Data Breaches to competent authorities and/or affected Data Subjects, if you are required to do so under Data Protection Laws.

Customer-Directed AI Agents. The Subscription Service includes an optional Model Context Protocol (MCP) interface that allows you to connect an AI agent of your choosing to your community. Where you enable it, the AI client and the model provider behind it are selected, configured and controlled by you under your own agreement with that provider; they are not Tightknit Sub-Processors, and Tightknit does not transmit Personal Data to any model provider in connection with this interface. Access is authorized against your users' existing roles and permissions in the Tightknit Studio, and the Personal Data returned to a connected agent is limited to what those permissions allow and to the communities that account may access. You remain responsible as Controller for your selection, configuration and use of any such agent, and you may disable the interface for your community at any time.

Deletion or Return of Personal Data. We will delete or return all Customer Data, including Personal Data (including copies thereof) Processed pursuant to this DPA, on termination or expiration of your Subscription Service. Following the termination or expiration of your Subscription Service, Tightknit will retain Customer Data, including Personal Data, for a period of thirty (30) days before initiating the deletion process as outlined herein. This term will apply except where we are required by applicable law to retain some or all of the Customer Data, or where we have archived Customer Data on back-up systems, which data we will securely isolate and protect from any further Processing and delete in accordance with our deletion practices. You may request the deletion of your Tightknit account after expiration or termination of your subscription by sending a request to support@tightknit.ai. Please review our Privacy Policy at https://www.tightknit.ai/legal/privacy-policy.

4. Data Subject Requests

The Subscription Service provides you with a number of controls that you can use to retrieve, correct, delete or restrict Personal Data, which you can use to assist you in connection with your obligations under Data Protection Laws, including your obligations relating to responding to requests from Data Subjects to exercise their rights under applicable Data Protection Laws ("Data Subject Requests").

To the extent that you are unable to independently address a Data Subject Request through the Subscription Service, then upon your written request we will provide reasonable assistance to you to respond to any Data Subject Requests or requests from data protection authorities relating to the Processing of Personal Data under the Agreement.

If a Data Subject Request or other communication regarding the Processing of Personal Data under the Agreement is made directly to us, we will promptly inform you and will advise the Data Subject to submit their request to you. You will be solely responsible for responding substantively to any such Data Subject Requests or communications involving Personal Data.

5. Sub-Processors

You agree we may engage Sub-Processors to Process Personal Data on your behalf, and we do so in two ways. First, we may engage Sub-Processors to assist us with hosting and infrastructure. Second, we may engage Sub-Processors to support product features and integrations.

We have currently appointed as Sub-Processors the third parties identified at https://trust.tightknit.ai, which is the authoritative list of our Sub-Processors and is referred to in Annex 3 to this DPA. Tightknit engages no Affiliate Sub-Processors; if that changes, we will notify you in accordance with this section.

Updating the maintained list does not by itself constitute notice. We will notify you of any new Sub-Processor by email, through our Slack community or through our Slack application, and you may object within 30 days as set out below. You may additionally subscribe to updates at https://trust.tightknit.ai to receive notifications directly. On request we will provide a copy of the Sub-Processor list as it stood on any specified date.

We will give you the opportunity to object to the engagement of new Sub-Processors on reasonable grounds relating to the protection of Personal Data within 30 days of notifying you. If you do notify us of such an objection, the parties will discuss your concerns in good faith with a view to achieving a commercially reasonable resolution. If no such resolution can be reached, we will, at our sole discretion, either not appoint the new Sub-Processor, or permit you to suspend or terminate the affected Subscription Service in accordance with the termination provisions of the Agreement without liability to either party (but without prejudice to any fees incurred by you prior to suspension or termination).

Where we engage Sub-Processors, we will impose data protection terms on the Sub-Processors that provide at least the same level of protection for Personal Data as those in this DPA, to the extent applicable to the nature of the services provided by such Sub-Processors. We will remain responsible for each 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.

6. Data Transfers

You acknowledge and agree that we may access and Process Personal Data on a global basis as necessary to provide the Subscription Service in accordance with the Agreement, and in particular that Personal Data may be transferred to and Processed by Tightknit, Inc. in the United States and to other jurisdictions where Tightknit Affiliates and Sub-Processors have operations. Wherever Personal Data is transferred outside its country of origin, each party will ensure such transfers are made in compliance with the requirements of Data Protection Laws.

7. Demonstration of Compliance

We will make all information reasonably necessary to demonstrate compliance with this DPA available to you and allow for and contribute to audits, including inspections conducted by you or your auditor in order to assess compliance with this DPA, where required by applicable law. You acknowledge and agree that you will exercise your audit rights under this DPA by instructing us to comply with the audit measures described in this section. You acknowledge that the Subscription Service is hosted by our hosting Sub-Processors who maintain independently validated security programs (including SOC 2 and ISO 27001), and that the Tightknit application is tested by independent third party penetration testing firms on at least an annual basis. Upon request, we will supply (on a confidential basis) our compliance reports and summary copies of our penetration testing report(s) to you so that you can verify our compliance with this DPA. Further, at your written request, we will provide written responses (on a confidential basis) to all reasonable requests for information made by you necessary to confirm our compliance with this DPA, provided that you will not exercise this right more than once per calendar year unless you have reasonable grounds to suspect non-compliance with the DPA.

8. Additional Provisions for European Data

Scope. This section will apply only with respect to European Data.

Roles of the Parties. When Processing European Data in accordance with your Instructions, the parties acknowledge and agree that you are acting as the Controller of European Data (either as the Controller, or as a Processor on behalf of another Controller) and we are the Processor under the Agreement.

Instructions. If we believe that your Instruction infringes European Data Protection Laws (where applicable), we will inform you without delay.

Data Protection Impact Assessments and Consultation with Supervisory Authorities. To the extent that the required information is reasonably available to us, and you do not otherwise have access to the required information, we will provide reasonable assistance to you with any data protection impact assessments, and prior consultations with supervisory authorities or other competent data privacy authorities to the extent required by European Data Protection Laws.

Transfer Mechanisms for Data Transfers. Tightknit will not transfer European Data to any country or recipient not recognized as providing an adequate level of protection for Personal Data (within the meaning of applicable European Data Protection Laws), unless it first takes all such measures as are necessary to ensure the transfer is in compliance with applicable European Data Protection Laws. Such measures may include (without limitation) (i) transferring such data to a recipient that is covered by a suitable framework or other legally adequate transfer mechanism recognized by the relevant authorities or courts as providing an adequate level of protection for Personal Data, including the Data Privacy Framework; (ii) to a recipient that has achieved binding corporate rules authorization in accordance with European Data Protection Laws; or (iii) to a recipient that has executed the Standard Contractual Clauses; in each case as adopted or approved in accordance with applicable European Data Protection Laws.

You acknowledge that in connection with the performance of the Subscription Services, Tightknit, Inc. is a recipient of European Data in the United States. To the extent that Tightknit, Inc. receives European Data in the United States, Tightknit, Inc. will comply with the following:

Data Privacy Framework. Tightknit, Inc. will use the Data Privacy Framework to lawfully receive European Data in the United States and ensure that it provides at least the same level of protection to such European Data as is required by the Data Privacy Framework Principles and will let you know if it is unable to comply with this requirement.

Standard Contractual Clauses. If European Data Protection Laws require that appropriate safeguards are put in place (for example, if the Data Privacy Framework does not cover the transfer to Tightknit, Inc. and/or the Data Privacy Framework is invalidated), the Standard Contractual Clauses will be incorporated by reference and form part of the Agreement as follows: in relation to European Data that is subject to the GDPR (i) Customer is the "data exporter" and Tightknit, Inc. is the "data importer"; (ii) the Module Two terms apply to the extent the Customer is a Controller of European Data and the Module Three terms apply to the extent the Customer is a Processor of European Data; (iii) in Clause 7, the optional docking clause applies; (iv) in Clause 9, Option 2 applies and changes to Sub-Processors will be notified in accordance with the Sub-Processors section of this DPA; (v) in Clause 11, the optional language is deleted; (vi) in Clauses 17 and 18, the parties agree that the Standard Contractual Clauses will be governed by the law of Ireland and that any dispute arising from them will be resolved before the courts of Ireland, in each case without reference to conflicts of law principles; (vii) the Annexes of the Standard Contractual Clauses will be deemed completed with the information set out in the Annexes of this DPA; (viii) the supervisory authority that will act as competent supervisory authority will be determined in accordance with GDPR; and (ix) if and to the extent the Standard Contractual Clauses conflict with any provision of this DPA the Standard Contractual Clauses will prevail to the extent of such conflict.

In relation to European Data that is subject to the UK GDPR, the Standard Contractual Clauses will apply in accordance with the preceding paragraph and the following modifications: (i) the Standard Contractual Clauses will be modified and interpreted in accordance with the UK Addendum, which will be incorporated by reference and form an integral part of the Agreement; (ii) Tables 1, 2 and 3 of the UK Addendum will be deemed completed with the information set out in the Annexes of this DPA and Table 4 will be deemed completed by selecting "neither party"; and (iii) any conflict between the terms of the Standard Contractual Clauses and the UK Addendum will be resolved in accordance with Section 10 and Section 11 of the UK Addendum.

In relation to European Data that is subject to the Swiss DPA, the Standard Contractual Clauses will apply with the following modifications: (i) references to "Regulation (EU) 2016/679" will be interpreted as references to the Swiss DPA; (ii) references to "EU", "Union" and "Member State law" will be interpreted as references to Swiss law; and (iii) references to the "competent supervisory authority" and "competent courts" will be replaced with "the Swiss Federal Data Protection and Information Commissioner" and the "relevant courts in Switzerland".

You agree that by complying with our obligations under the Sub-Processors section of this DPA, Tightknit, Inc. fulfills its obligations under Section 9 of the Standard Contractual Clauses. For the purposes of Clause 9(c) of the Standard Contractual Clauses, you acknowledge that we may be restricted from disclosing Sub-Processor agreements but we will use reasonable efforts to require any Sub-Processor we appoint to permit it to disclose the Sub-Processor agreement to you and will provide (on a confidential basis) all information we reasonably can. You also acknowledge and agree that you will exercise your audit rights under Clause 8.9 of the Standard Contractual Clauses by instructing us to comply with the measures described in the Demonstration of Compliance section of this DPA.

Alternative Transfer Mechanism. In the event that Tightknit is required to adopt an alternative transfer mechanism for European Data, in addition to or other than the mechanisms described above, such alternative transfer mechanism will apply automatically instead of the mechanisms described in this DPA (but only to the extent such alternative transfer mechanism complies with European Data Protection Laws), and you agree to execute such other documents or take such action as may be reasonably necessary to give legal effect to such alternative transfer mechanism.

9. Additional Provisions for California Personal Information

Scope. This section will apply only with respect to California Personal Information.

Roles of the Parties. When processing California Personal Information in accordance with your Instructions, the parties acknowledge and agree that you are a Business and we are a Service Provider for the purposes of the CCPA.

Responsibilities. We certify that we will Process California Personal Information as a Service Provider strictly for the purpose of performing the Subscription Services and Consulting Services under the Agreement (the "Business Purpose") or as otherwise permitted by the CCPA, including as described in the Usage Data section of our Privacy Policy. Further, we certify we (i) will not Sell or Share California Personal Information; (ii) will not Process California Personal Information outside the direct business relationship between the parties, unless required by applicable law; and (iii) will not combine the California Personal Information included in Customer Data with personal information that we collect or receive from another source (other than information we receive from another source in connection with our obligations as a Service Provider under the Agreement).

Compliance. We will (i) comply with obligations applicable to us as a Service Provider under the CCPA and (ii) provide California Personal Information with the same level of privacy protection as is required by the CCPA. We will notify you if we make a determination that we can no longer meet our obligations as a Service Provider under the CCPA.

CCPA Audits. You will have the right to take reasonable and appropriate steps to help ensure that we use California Personal Information in a manner consistent with your obligations under the CCPA. Upon notice, you will have the right to take reasonable and appropriate steps in accordance with the Agreement to stop and remediate unauthorized use of California Personal Information.

Not a Sale. The parties acknowledge and agree that the disclosure of California Personal Information by the Customer to Tightknit does not form part of any monetary or other valuable consideration exchanged between the parties.

10. General Provisions

Amendments. Notwithstanding anything else to the contrary in the Agreement, and without prejudice to the 'Compliance with Instructions' or 'Security' sections of this DPA, we may update this DPA from time to time. Where an update materially reduces your rights or increases your obligations, we will notify you and you may terminate the affected Subscription Service as described at the beginning of this DPA. For the avoidance of doubt, the requirement in Section 9 (Miscellaneous) of the Terms and Conditions that modifications be in writing and signed by both parties does not apply to updates made under this section.

Severability. If any individual provisions of this DPA are determined to be invalid or unenforceable, the validity and enforceability of the other provisions of this DPA will not be affected.

Limitation of Liability. Each party and each of their Affiliates' liability, taken in aggregate, arising out of or related to this DPA (including any other DPAs between the parties) and the Standard Contractual Clauses, where applicable, whether in contract, tort or under any other theory of liability, will be subject to the limitations and exclusions of liability set out in Section 8 (Limitation of Liability) of the Terms and Conditions, and any reference in that section to the liability of a party means the aggregate liability of that party and all of its Affiliates under the Agreement (including this DPA). For the avoidance of doubt, if Tightknit, Inc. is not a party to the Agreement, Section 8 of the Terms and Conditions will apply as between you and Tightknit, Inc., and in such respect any references to "Tightknit", "we", "us" or "our" will include both Tightknit, Inc. and the Tightknit entity that is a party to the Agreement. In no event will either party's liability be limited with respect to any individual's data protection rights under this DPA or otherwise.

Governing Law. This DPA will be governed by and construed in accordance with the laws of the State of New York, without regard to its conflict of laws provisions, consistent with Section 9 (Miscellaneous) of the Terms and Conditions, unless required otherwise by Data Protection Laws. This is without prejudice to the governing law and forum specified for the Standard Contractual Clauses in the 'Additional Provisions for European Data' section above.

11. Parties to this DPA

Permitted Affiliates. By signing the Agreement, you enter into this DPA (including, where applicable, the Standard Contractual Clauses) on behalf of yourself and in the name and on behalf of your Permitted Affiliates. For the purposes of this DPA only, and except where indicated otherwise, the terms "Customer", "you" and "your" will include you and such Permitted Affiliates.

Authorization. The legal entity agreeing to this DPA as Customer represents that it is authorized to agree to and enter into this DPA for and on behalf of itself and, as applicable, each of its Permitted Affiliates.

Remedies. The parties agree that (i) solely the Customer entity that is the contracting party to the Agreement will exercise any right or seek any remedy any Permitted Affiliate may have under this DPA on behalf of its Affiliates, and (ii) the Customer entity that is the contracting party to the Agreement will exercise any such rights under this DPA not separately for each Permitted Affiliate individually but in a combined manner for itself and all of its Permitted Affiliates together. The Customer entity that is the contracting entity is responsible for coordinating all Instructions, authorizations and communications with us under the DPA and will be entitled to make and receive any communications related to this DPA on behalf of its Permitted Affiliates.

Other rights. The parties agree that you will, when reviewing our compliance with this DPA pursuant to the Demonstration of Compliance section, take all reasonable measures to limit any impact on us and our Affiliates by combining several audit requests carried out on behalf of the Customer entity that is the contracting party to the Agreement and all of its Permitted Affiliates in one single audit.

Annex 1 — Details of Processing

A. List of Parties

Data exporter: The Customer, as defined in the Tightknit Sales Agreement (on behalf of itself and Permitted Affiliates). Address and contact details as set out in the Order Form and/or the Customer's Tightknit account. Role: Controller (either as the Controller, or acting in the capacity of a Controller, as a Processor, on behalf of another Controller).

Data importer: Tightknit, Inc., 135 E 17th St, New York, NY 10003 USA. Contact: Zachary Hawtof, Chief Executive Officer. Role: Processor.

Activities relevant to the data transferred: Processing of Personal Data in connection with Customer's use of the Tightknit Subscription Services under the Tightknit Sales Agreement.

B. Description of Transfer

Categories of Data Subjects whose Personal Data is Transferred. You may submit Personal Data in the course of using the Subscription Service, the extent of which is determined and controlled by you in your sole discretion, and which may include, but is not limited to, Personal Data relating to your contacts and other end users including your employees, contractors, collaborators, customers, prospects, suppliers and subcontractors. Data Subjects may also include individuals attempting to communicate with or transfer Personal Data to your end users.

Categories of Personal Data Transferred. You may submit Personal Data to the Subscription Services, the extent of which is determined and controlled by you in your sole discretion, and which may include but is not limited to the following categories:

• Contact and Identifiers — Name, email address, usernames, display names, and profile photos or avatars.
• Account, Roles, and Permissions — Tenant membership, role or permission sets, team membership flags, and administrative status.
• Workspace Content (if Slack is connected) — Messages, threads, replies, reactions, channel membership, message timestamps, and related metadata.
• Files and Attachments — Files referenced in messages or posts and associated metadata such as filenames, sizes, and mime types.
• Usage and Technical Data — IP address, device identifiers, cookies, telemetry data, feature usage, pages viewed, and timestamps.
• Administrative Configuration and Support Interactions — Settings, audit logs of administrative actions, support tickets, and related communications.
• Optional Integrations Data (if enabled by Customer) — Limited CRM contact fields and activity mappings for integrated systems such as Salesforce, for workflow and reporting purposes.
• Derived and Analytics Data — Aggregated or de-identified metrics used for performance, reliability, and product improvement. Tightknit does not re-identify such data.
• Special Categories of Data — Not intentionally collected or processed. Customer shall not submit special category data unless expressly agreed and subject to additional safeguards.

Sensitive Data. The parties do not anticipate the transfer of sensitive data.

Frequency of the transfer. Continuous.

Nature of the Processing. Personal Data will be Processed in accordance with the Agreement (including this DPA) and may be subject to the following Processing activities: (1) storage and other Processing necessary to provide, maintain and improve the Subscription Services provided to you; (2) where you enable the optional Model Context Protocol interface, retrieval and modification of Customer Data at the direction of an AI agent you have connected and authorized, within the permissions of the Tightknit Studio user on whose behalf it acts; and (3) disclosure in accordance with the Agreement (including this DPA) and/or as compelled by applicable laws.

Purpose of the transfer and further processing. We will Process Personal Data as necessary to provide the Subscription Services pursuant to the Agreement, as further specified in the Order Form, and as further instructed by you in your use of the Subscription Services.

Period for which Personal Data will be retained. Subject to the Deletion or Return of Personal Data section of this DPA, we will Process Personal Data for the duration of the Agreement, unless otherwise agreed in writing. Operational and diagnostic records that support the security and reliability of the Subscription Service are retained on defined schedules independent of the Agreement term: application error logs for 30 days, product usage telemetry for up to 84 months, and infrastructure audit logs for the life of the relevant infrastructure account.

Annex 2 — Security Measures

We currently observe the Security Measures described in this Annex 2. All capitalized terms not otherwise defined herein will have the meanings set forth in this DPA or in the Terms and Conditions within the Tightknit Sales Agreement.

a) Access Control

Outsourced processing. We host our Service with outsourced cloud infrastructure providers. Additionally, we maintain contractual relationships with vendors in order to provide the Service in accordance with our DPA. We rely on contractual agreements, privacy policies, and vendor compliance programs in order to protect data processed or stored by these vendors.

Physical and environmental security. We host our product infrastructure with multitenant, outsourced infrastructure providers. We do not own or maintain hardware located at the outsourced infrastructure providers' data centers. Production environments are logically separated from our internal corporate information systems. The infrastructure providers' security controls are audited for SOC 2 Type II and ISO 27001 compliance, among other certifications.

Authentication. Authentication to the Tightknit Studio is delegated to a dedicated identity provider that supports single sign-on and multi-factor authentication. Customers who interact with the products via the user interface must authenticate before accessing non-public customer data. Tightknit does not store end-user passwords.

Authorization. Customer Data is stored in multi-tenant storage systems accessible to Customers only via application user interfaces and application programming interfaces. Customers are not allowed direct access to the underlying application infrastructure. Tenant isolation is enforced at the database layer using row-level security. The authorization model is designed to ensure that only the appropriately assigned individuals can access relevant features, views, and customization options, and authorization is evaluated per request against the user's assigned roles and permissions.

Programmatic and agent access. Public product APIs may be accessed using a scoped API key. The optional Model Context Protocol interface uses OAuth 2.1 with no long-lived credentials issued, and every request is authorized against the signed-in user's existing Studio roles and permissions and scoped to the communities that account may access.

Access controls. Network access control mechanisms are designed to prevent network traffic using unauthorized protocols from reaching the product infrastructure. The technical measures implemented differ between infrastructure providers and include security group assignment and firewall rules.

Intrusion detection and prevention. We implement a Web Application Firewall (WAF) solution to protect hosted customer websites and other internet-accessible applications. The WAF is designed to identify and prevent attacks against publicly available network services.

Static code analysis. Code stored in our source code repositories is checked for best practices and identifiable software flaws using automated tooling, including dependency scanning and static analysis that run on pull requests.

Penetration testing. We maintain relationships with industry-recognized penetration testing service providers for penetration testing of the Tightknit web application and its supporting services on at least an annual basis. The intent of these penetration tests is to identify security vulnerabilities and mitigate the risk and business impact they pose to the in-scope systems.

Product access. A subset of our employees have access to the products and to customer data via controlled interfaces, in order to provide effective customer support, product development and research, to troubleshoot potential problems, and to detect and respond to security incidents. Employees are granted access by role, and access is reviewed on a periodic basis.

Background checks. Where permitted by applicable law, Tightknit employees undergo a third-party background or reference check. In the United States, employment offers are contingent upon the results of a third-party background check. All Tightknit employees are required to conduct themselves in a manner consistent with company guidelines, non-disclosure requirements, and ethical standards.

b) Transmission Control

In-transit. We require HTTPS encryption (also referred to as SSL or TLS) on all login interfaces and on every customer site hosted on the Tightknit products. Our HTTPS implementation uses industry standard algorithms and certificates.

At-rest. We have implemented technologies to ensure that stored data is encrypted at rest.

c) Input Control

Detection. Our infrastructure is designed to log information about system behavior, traffic received, system authentication, and application requests. Log data is aggregated in centralized log management and error monitoring systems, and automated alerts notify the engineering team of error conditions and anomalous system behavior. Our personnel are responsive to known incidents.

Response and tracking. We maintain a record of known security incidents that includes description, dates and times of relevant activities, and incident disposition. Suspected and confirmed security incidents are investigated by security, operations, or support personnel, and appropriate resolution steps are identified and documented. For any confirmed incidents, we will take appropriate steps to minimize product and Customer damage or unauthorized disclosure. Notification to you will be in accordance with the Personal Data Breaches section of this DPA.

d) Availability Control

Infrastructure availability. The infrastructure providers use commercially reasonable efforts to ensure a minimum of 99.95% uptime. The providers maintain a minimum of N+1 redundancy to power, network, and heating, ventilation and air conditioning (HVAC) services.

Fault tolerance. Backup and replication strategies are designed to provide redundancy and recovery during a significant processing failure. Customer data is backed up to durable data stores on a recurring basis, and point-in-time recovery is available for the primary database.

Disaster Recovery Plans. We maintain business continuity and disaster recovery plans with defined recovery time and recovery point objectives, and we test them on at least an annual basis and document the results. Our products are architected with a goal of avoiding single points of failure and limiting downtime during maintenance and updates.

Annex 3 — Sub-Processors

This Annex 3 is incorporated into the DPA and the Agreement. Tightknit maintains a single authoritative list of its Sub-Processors at https://trust.tightknit.ai. That list, as it stands from time to time, constitutes Annex 3 for the purposes of this DPA and completes Annex III of the Standard Contractual Clauses where those clauses apply. By agreeing to the DPA, you agree that the Sub-Processors identified there may have access to Customer Data.

The list distinguishes Core Sub-Processors, which support the Subscription Service for all customers, from Optional Sub-Processors, which are engaged only where you enable the related feature. Our business needs and service providers change from time to time: we may remove a provider in order to consolidate our supply chain, or add one where we believe doing so improves the Subscription Service. Changes are notified in accordance with the Sub-Processors section of this DPA, and on request we will provide a copy of the list as it stood on any specified date.