Zip Infosolutions Pvt Ltd - Data Protection Addendum

Annex 1 to Data Protection Addendum

Description of Processing Activities for Customer Personal Data

1.  List of Parties
   Data Exporter

   Name:	Customer (as defined in the Agreement)
   Address:	As set forth in the relevant Order Form.
   Contact person’s name, position and contact details:	As set forth in the relevant Order Form.
   Activities relevant to the data transferred under these Clauses:	Recipient of the Services provided by Growisto in accordance with the Agreement.
   Signature and date:	Signature and date are set out in the Agreement.
   Role (controller/processor):	Controller
   Data Importer Name:	Zip Infosolutions Privat Limited
   Address:	1st and 2nd Floor, Kagalwala House, Plot No. 175, Near Metro House, CST Road, Kalina, BKC, Santacruz-East, Mumbai Bandra Suburban, Mumbai, Maharashtra 400098
   Contact person’s name, position and contact details:	Gunjan Agrawal, gunjan.agrawal@growisto.com
   Activities relevant to the data transferred under these Clauses:	Provision of the Services to the Customer in accordance with the Agreement.
   Signature and date:	Signature and date are set out in the Agreement.
   Role (controller/processor):	Processor

2. Competent Supervisory Authority

   Identify the competent supervisory authority/ies in accordance (e.g. in accordance with Clause 13 SCCs)

   As determined by application of Clause 13 of the EU SCCs.

3. Processing Information

   Categories of data subjects whose personal data is transferred	Customer’s authorized users of the Services
   Categories of personal data transferred	Processed automatically by the Services: · Names · Email IDs Processed where and to the extent provided by Customer or its authorized users in connection with audit services provided by Growisto: · Address · Date of birth · Past employment details
   Sensitive personal data transferred	None
   Frequency of the transfer	Continuous
   Nature of the processing	The nature of the processing is more fully described in the Agreement and accompanying order forms but will include the following basic processing activities: The provision of Services to Customer. In order to provide people data, Growisto receives identifying Customer Personal Data to permit Growisto to query, cleanse, standardize, enrich, (when required) send additional data to feed providers, and to store the query information. The purpose of the transfer is to facilitate the performance of the Services more fully described in the Agreement and accompanying order forms.
   Purpose of the data transfer and further processing
   For processing involving California consumers, please select the Business Purpose(s) for Processing Personal Data	☐ N/A ☐ Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards ☒ Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes ☒ Debugging to identify and repair errors that impair existing intended functionality. ☐ Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer’s current interaction with the business, provided that the consumer’s personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business ☒ Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business. ☐ Providing advertising and marketing services, except for cross-context behavioral advertising, to the consumer provided that, for the purpose of advertising and marketing, a service provider or contractor shall not combine the personal information of opted-out consumers that the service provider or contractor receives from, or on behalf of, the business with personal information that the service provider or contractor receives from, or on behalf of, another person or persons or collects from its own interaction with consumers. ☒ Undertaking internal research for technological development and demonstration. ☒ Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for or controlled by the business. ☒ To retain and employ another service provider or contractor as a subcontractor where the subcontractor meets the requirements for a service provider or contractor under CCPA. ☒ To build or improve the quality of the services it is providing to the business even if this Business Purpose is not specified in the written contract required by CCPA provided that Service Provider does not use the Customer Personal Data to perform Services on behalf of another person. ☒ To prevent, detect, or investigate data security incidents or protect against malicious, deceptive, fraudulent, or illegal activity, even if this Business Purpose is not specified in the written contract.
   Period for which the personal data will be retained or criteria used to determine that period	The period for which the Customer Personal Data will be retained is more fully described in the Agreement, Addendum, and accompanying order forms.
   Subprocessor transfers – subject matter, nature, and duration of processing	The subject matter, nature, and duration of the Processing more fully described in the Agreement, Addendum, and accompanying order forms.

4. Technical and Organisational Security MeasuresDescription of the  technical and organisational security measures implemented by Growisto as the data processor/data importer to ensure an appropriate level of security, taking into account the nature, scope, context, and purpose of the processing, and the risks for the rights and freedoms of natural persons.
   • Security
     • Security Management System.
       • Organization. Growisto designates qualified security personnel whose responsibilities include development, implementation, and ongoing maintenance of the Information Security Program.
       • Policies. Management reviews and supports all security related policies to ensure the security, availability, integrity and confidentiality of Customer Personal Data.  These policies are updated at least once annually.
       • Assessments. Growisto engages a reputable independent third-party to perform risk assessments of all systems containing Customer Personal Data at least once annually.
       • Risk Treatment. Growisto maintains a formal and effective risk treatment program that includes penetration testing, vulnerability management and patch management to identify and protect against potential threats to the security, integrity or confidentiality of Customer Personal Data.
       • Vendor Management. Growisto maintains an effective vendor management program
       • Incident Management. Growisto reviews security incidents regularly, including effective determination of root cause and corrective action.
       • Standards. Growisto operates an information security management system that complies with the requirements of ISO/IEC 27001:2013 standard.
     • Personnel Security.
       • Growisto personnel are required to conduct themselves in a manner consistent with the company’s guidelines regarding confidentiality, business ethics, appropriate usage, and professional standards. Growisto conducts reasonably appropriate background checks on any employees who will have access to client data under this Agreement, including in relation to employment history and criminal records, to the extent legally permissible and in accordance with applicable local labor law, customary practice and statutory regulations.
       • Personnel are required to execute a confidentiality agreement in writing at the time of hire and to protect Customer Personal Data at all times. Personnel must acknowledge receipt of, and compliance with, Growisto’s confidentiality, privacy and security policies. Personnel are provided with privacy and security training on how to implement and comply with the Information Security Program. Personnel handling Customer Personal Data are required to complete additional requirements appropriate to their role (e.g., certifications). Growisto’s personnel will not process Customer Personal Data without authorization.
     • Access Controls
       • Access Management. Growisto maintains a formal access management process for the request, review, approval and provisioning of all personnel with access to Customer Personal Data to limit access to Customer Personal Data and systems storing, accessing or transmitting Customer Personal Data to properly authorized persons having a need for such access. Access reviews are conducted periodically to ensure that only those personnel with access to Customer Personal Data still require it.
       • Infrastructure Security Personnel. Growisto has, and maintains, a security policy for its personnel, and requires security training as part of the training package for its personnel. Growisto’s infrastructure security personnel are responsible for the ongoing monitoring of Growisto’s security infrastructure, the review of the Services, and for responding to security incidents.
       • Access Control and Privilege Management. Growisto’s and Customer’s administrators and end users must authenticate themselves via a Multi-Factor authentication system or via a single sign on system in order to use the Services
       • Internal Data Access Processes and Policies – Access Policy. Growisto’s internal data access processes and policies are designed to protect against unauthorized access, use, disclosure, alteration or destruction of Customer Personal Data. Growisto designs its systems to only allow authorized persons to access data they are authorized to access based on principles of “least privileged” and “need to know”, and to prevent others who should not have access from obtaining access.  Growisto requires the use of unique user IDs, strong passwords, two factor authentication and carefully monitored access lists to minimize the potential for unauthorized account use. The granting or modification of access rights is based on: the authorized personnel’s job responsibilities; job duty requirements necessary to perform authorized tasks; a need to know basis; and must be in accordance with Growisto’s internal data access policies and training. Approvals are managed by workflow tools that maintain audit records of all changes. Access to systems is logged to create an audit trail for accountability. Where passwords are employed for authentication (e.g., login to workstations), password policies follow industry standard practices. These standards include password complexity, password expiry, password lockout, restrictions on password reuse and re-prompt for password after a period of inactivity
     • Data Center and Network Security
       • Our website is hosted on Hostinger’s data centers, which are designed to provide reliable and efficient hosting for WordPress-based websites.
       • Infrastructure – Our infrastructure is managed entirely by Hostinger. The hosting environment is optimized for WordPress websites, ensuring stable performance and scalability. We rely on Hostinger’s services for server security, performance, and updates.
       • Resiliency – Hostinger employs server-side resiliency measures, including data redundancy and regular server maintenance. While the website does not implement custom multi-availability zones or regular backup restoration tests, we leverage Hostinger’s automatic backups feature to protect your data.
       • Server Operating Systems – Hostinger manages the operating system and hosting environment. The website operates within a shared, cloud hosting framework tailored for WordPress, with automatic security updates and optimizations applied by Hostinger.
       • Disaster Recovery – Hostinger provides automatic backups as part of our hosting plan. We ensure data safety by enabling daily or weekly backups through the Hostinger dashboard. While no custom disaster recovery testing is conducted, Hostinger’s managed hosting services include recovery options in case of accidental data loss.
       • Security Logs – Hostinger includes basic logging and monitoring capabilities for our hosting environment. These logs help detect potential issues, and any intrusions are managed by Hostinger’s internal security protocols.
       • Vulnerability Management – We rely on Hostinger’s regular server updates and security measures to ensure a secure environment. WordPress core updates, plugins, and themes are kept up-to-date manually to minimize vulnerabilities. Critical patches are applied as soon as they are available through WordPress or Hostinger’s infrastructure..
       • Networks and Transmission.
         • Data Transmission. Transmissions on production environment are transmitted via Internet standard protocols.
         • Incident Response. Growisto maintains incident management policies and procedures, including detailed security incident escalation procedures. Growisto monitors a variety of communication channels for security incidents, and Growisto’s security personnel will react promptly to suspected or known incidents, mitigate harmful effects of such security incidents, and document such security incidents and their outcomes.
         • Encryption Technologies. Growisto makes HTTPS encryption (also referred to as SSL or TLS) available for data in transit and implements encryption technologies for data at rest to ensure the security and confidentiality of Customer Data.
       • Data Storage, Isolation, Authentication, and Destruction. Growisto stores data in a multi-tenant environment on AWS servers. Data, the Services database and file system architecture are replicated between multiple availability zones on AWS. Growisto logically isolates the data of different customers. A central authentication system is used across all Services to increase uniform security of data. Growisto ensures secure disposal of Client Data through the use of a series of data destruction processes.