← Priimal Vantage

Data Processing Agreement

Effective date: 1 October 2026 — Priimal Technologies Ltd.

Executed DPA Required for Enterprise Tiers

Enterprise customers (Reveal, Recover, Resolve tiers) processing personal data must execute a signed DPA with Priimal Technologies. Contact legal@priimal.com to initiate.

1. Subject Matter

This Data Processing Agreement ("DPA") supplements the Terms of Service between Priimal Technologies Ltd ("Processor") and the Customer ("Controller") and governs the processing of personal data by Priimal in connection with the Vantage Service.

2. Nature and Purpose of Processing

Priimal processes personal data solely to provide the Vantage Service as described in the Terms of Service: scoring, flagging, and presenting insights from datasets uploaded by the Controller. Processing is conducted only on documented instructions from the Controller.

3. Categories of Data Subjects and Data

Data subjects and data categories are determined by the Controller based on the datasets they upload. Typically these include individual or business records relating to transactions, claims, accounts, or counterparties.

4. Duration

Processing continues for the duration of the Service agreement. Upon termination, Priimal will delete or return data within 30 days as directed by the Controller.

5. Obligations of the Processor

Priimal will: (a) process data only on Controller instructions; (b) maintain appropriate technical and organisational security measures; (c) ensure persons authorised to process data are bound by confidentiality obligations; (d) assist the Controller in fulfilling data subject rights; (e) notify the Controller without undue delay of any personal data breach.

6. Sub-processors

Priimal uses sub-processors to deliver the Service. The current list is available at legal@priimal.com. Priimal will provide 30 days' notice of sub-processor changes, giving the Controller the right to object.

7. International Transfers

Where personal data is transferred outside the EEA, Priimal will ensure appropriate safeguards are in place, such as EU Standard Contractual Clauses.

8. Audits

Priimal will make available to the Controller all information necessary to demonstrate compliance with this DPA, and will allow for and contribute to audits or inspections conducted by the Controller or a mandated auditor.

9. Contact

To execute a signed DPA or with questions, contact legal@priimal.com.

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