GDPR Data Processing Agreement

This Fatica Consulting L.L.C. Data Processing Agreement (“DPA”), that includes the Standard Contractual Clauses adopted by the European Commission, as applicable, reflects the parties’ agreement with respect to the terms governing the Processing of Personal Data under the MetaLocator Terms of Use (the “Agreement”). This DPA is an amendment to the Agreement and is effective upon its incorporation into the Agreement, which incorporation may be specified in the Agreement, an Order or an executed amendment to the Agreement. Upon its incorporation into the Agreement, the DPA will form a part of the Agreement.

The term of this DPA shall follow the term of the Agreement. Terms not otherwise defined herein shall have the meaning as set forth in the Agreement.

THIS DPA INCLUDES:

(i) Standard Contractual Clauses, attached hereto as EXHIBIT 1.

(a) Annex 1 to the Standard Contractual Clauses, which includes specifics on the Personal Data transferred by the data exporter to the data importer.

(b) Annex 2 to the Standard Contractual Clauses, which includes a description of the technical and organizational security measures implemented by the data importer as referenced.

(ii) List of Sub-Processors, attached hereto as EXHIBIT 2.

1. Definitions

“Customer” or “Controller” means the entity (individual or organization) that determines the purposes and means of the Processing of Personal Data submitted, stored, sent, or received through the Services. For the purposes of this DPA and the Agreement, the Customer acts as the Controller (as defined in Data Protection Law) of Personal Data and Fatica Consulting L.L.C. acts as the Processor.
 
 Where the Customer acts on behalf of its own end-clients or affiliates, the Customer is responsible for ensuring it has the lawful authority to act as Controller (or to appoint Fatica Consulting L.L.C. as Processor) in respect of the Personal Data provided.

“Data Protection Law” means all applicable legislation relating to data protection and privacy including without limitation the Regulation (EU) 2016/679 (GDPR) and all local laws and regulations which amend or replace any of them, including the GDPR, together with any national implementing laws in any Member State of the European Union or, to the extent applicable, in any other country, as amended, repealed, consolidated or replaced from time to time. The terms “process”, “processes” and “processed” will be construed accordingly.

“Data Subject” means the individual to whom Personal Data relates.

“GDPR” means the General Data Protection 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 and on the free movement of such data.

“Instruction” means the written, documented instruction, issued by Controller to Processor, and directing the same to perform a specific action with regard to Personal Data (including, but not limited to, depersonalizing, blocking, deletion, making available).

“Personal Data” means any information relating to an identified or identifiable individual where such information is contained within Customer Data and is protected similarly as personal data or personally identifiable information under applicable Data Protection Law

“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.

“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.

“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 clauses attached hereto as Exhibit 1 pursuant to the European Commission under Commission Implementing Decision (EU) 2021/914 of 4 June 2021 for the transfer of personal data to processors established in third countries which do not ensure an adequate level of data protection.

2. Details of the Processing

a. Categories of Data Subjects. Controller’s Contacts and other end users including Controller’s employees, contractors, collaborators, customers, prospects, location managers, location contacts, leads, suppliers and subcontractors. Data Subjects also include individuals attempting to communicate with or transfer Personal Data to the Controller’s end users. Controller agrees not to export, import or copy, in whole or in part to Processor’s systems highly sensitive personal data including any issued identification, health history, criminal convictions and offences, social security numbers, drivers license numbers, credit card information, dates of birth, names of parents/guardians, any personal information of persons under the age of 16.

b. Types of Personal Data. Contact Information, the extent of which is determined and controlled by the Customer in its sole discretion, and other Personal Data such as navigational data (including website usage information), location data, partner data, email data, system usage data, application integration data, and other electronic data submitted, stored, sent, or received by end users via the Service. Due to the nature of Processor’s software, Customer may supply data of any type, within the limits of this agreement.  Customer acknowledges that Processor does not, but reserves the right to, physically audit, review, approve or remove Customer-provided data.  It is the Customer’s sole responsibility to ensure that the Personal Data provided to Processor is provided within the Customer’s rights and in a manner that is compliant with the statutory requirements relating to data protection and privacy, in particular regarding the disclosure and transfer of Personal Data to the Processor and the Processing of Personal Data.

c. Subject-Matter and Nature of the Processing. The subject-matter of Processing of Personal Data by Processor is the provision of the services to the Controller that involves the Processing of Personal Data. Personal Data will be subject to those Processing activities as may be specified in the Agreement and an Order.

d. Purpose of the Processing. Personal Data will be Processed for purposes of providing the services set out and otherwise agreed to in the Agreement and any applicable Order.

e. Duration of the Processing. Personal Data will be Processed for the duration of the Agreement, subject to Section 4 of this DPA.

3. Customer Responsibility

Within the scope of the Agreement and in its use of the services, Controller shall be solely responsible for complying with the statutory requirements relating to data protection and privacy, in particular regarding the disclosure and transfer of Personal Data to the Processor and the Processing of Personal Data. For the avoidance of doubt, Controller’s instructions for the Processing of Personal Data shall comply with the Data Protection Law. This DPA is Customer’s complete and final instruction to Fatica Consulting L.L.C. in relation to Personal Data and that additional instructions outside the scope of DPA would require prior written agreement between the parties. Instructions shall initially be specified in the Agreement and may, from time to time thereafter, be amended, amplified or replaced by Controller in separate written instructions (as individual instructions).

Controller shall inform Processor without undue delay and comprehensively about any errors or irregularities related to statutory provisions on the Processing of Personal Data.

4. Obligations of Processor

a. Compliance with Instructions. The parties acknowledge and agree that Customer is the Controller of Personal Data and Fatica Consulting L.L.C. is the Processor of that data. Processor shall collect, process and use Personal Data only within the scope of Controller’s Instructions. If the Processor believes that an Instruction of the Controller infringes the Data Protection Law, it shall immediately inform the Controller without delay. If Processor cannot process Personal Data in accordance with the Instructions due to a legal requirement under any applicable European Union or Member State law, Processor will (i) promptly notify the Controller of that legal requirement before the relevant Processing to the extent permitted by the Data Protection Law; and (ii) cease all Processing (other than merely storing and maintaining the security of the affected Personal Data) until such time as the Controller issues new instructions with which Processor is able to comply. If this provision is invoked, Processor will not be liable to the Controller under the Agreement for any failure to perform the applicable services until such time as the Controller issues new instructions in regard to the Processing.

b. Security. Processor shall take the appropriate technical and organizational measures to adequately protect Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to Personal Data, described under Annex II to the Standard Contractual Clauses. Such measures include, but are not limited to:

i. the prevention of unauthorized persons from gaining access to Personal Data Processing systems (physical access control),

ii. the prevention of Personal Data Processing systems from being used without authorization (logical access control),

iii. ensuring that persons entitled to use a Personal Data Processing system gain access only to such Personal Data as they are entitled to accessing in accordance with their access rights, and that, in the course of Processing or use and after storage, Personal Data cannot be read, copied, modified or deleted without authorization (data access control),

iv. ensuring that Personal Data cannot be read, copied, modified or deleted without authorization during electronic transmission, transport or storage on storage media, and that the target entities for any transfer of Personal Data by means of data transmission facilities can be established and verified (data transfer control),

v. ensuring the establishment of an audit trail to document whether and by whom Personal Data have been entered into, modified in, or removed from Personal Data Processing systems (entry control),

vi. ensuring that Personal Data is Processed solely in accordance with the Instructions (control of instructions),

vii. ensuring that Personal Data is protected against accidental destruction or loss (availability control).

Upon Controller’s request, Processor shall provide a current Personal Data protection and security program relating to the Processing hereunder.

Processor will facilitate Controller’s compliance with the Controller’s obligation to implement security measures with respect to Personal Data (including if applicable Controller’s obligations pursuant to Articles 32 to 34 (inclusive) of the GDPR), by (i) implementing and maintaining the security measures described under Annex II, (ii) complying with the terms of Section 4.d (Personal Data Breaches); and (iii) providing the Controller with information in relation to the Processing in accordance with Section 5 (Audits).

c. Confidentiality.  Processor shall ensure that any personnel whom Processor authorizes to process Personal Data on its behalf is subject to confidentiality obligations with respect to that Personal Data. The undertaking to confidentiality shall continue after the termination of the above-entitled activities.

d. Personal Data Breaches. Processor will notify the Controller as soon as practicable after it becomes aware of any of any Personal Data Breach affecting any Personal Data. At the Controller’s request, Processor will promptly provide the Controller with all reasonable assistance necessary to enable the Controller to notify relevant Personal Data Breaches to competent authorities and/or affected Data Subjects, if Controller is required to do so under the Data Protection Law.

e. Data Subject Requests. Processor will provide reasonable assistance, including by appropriate technical and organizational measures and taking into account the nature of the Processing, to enable Controller to respond to any request from Data Subjects seeking to exercise their rights under the Data Protection Law with respect to Personal Data (including access, rectification, restriction, deletion or portability of Personal Data, as applicable), to the extent permitted by the law.  If such request is made directly to Processor, Processor will promptly inform Controller and will advise Data Subjects to submit their request to the Controller. Controller shall be solely responsible for responding to any Data Subjects’ requests. Controller shall reimburse Processor for the costs arising from this assistance.

f. Sub-Processors. Processor shall be entitled to engage sub-Processors to fulfil Processor’s obligations defined in the Agreement only with Controller’s written consent.  For these purposes, Controller consents to the engagement as sub-Processors of Processor’s affiliated companies and the third parties listed in Exhibit 2. For the avoidance of doubt, the above authorization constitutes Controller’s prior written consent to the sub-Processing by Processor for purposes of Clause 11 of the Standard Contractual Clauses.

g. Where Fatica Consulting L.L.C. has self-certified under the EU–U.S. Data Privacy Framework such certification shall serve as an alternative lawful data transfer mechanism for transfers to the United States.

If the Processor intends to instruct sub-Processors other than the companies listed in Exhibit 2, the Processor will notify the Controller thereof in writing (email to the email address(es) on record in Processor’s account information for Controller is sufficient) and will give the Controller the opportunity to object to the engagement of the new sub-Processors within 30 days after being notified. The objection must be based on reasonable grounds (e.g. if the Controller proves that significant risks for the protection of its Personal Data exist at the sub-Processor). If the Processor and Controller are unable to resolve such objection, either party may terminate the Agreement by providing written notice to the other party. Controller shall receive a refund of any prepaid but unused fees for the period following the effective date of termination.

Where Processor engages sub-Processors, Processor will enter into a contract with the sub-Processor that imposes on the sub-Processor equivalent obligations that apply to Processor under this DPA. Where the sub-Processor fails to fulfil its data protection obligations, Processor will remain liable to the Controller for the performance of such sub-Processors obligations.

Where a sub-Processor is engaged, the Controller must be granted the right to monitor and inspect the sub-Processor’s activities in accordance with this DPA and the Data Protection Law, including to obtain information from the Processor, upon written request, on the substance of the contract and the implementation of the data protection obligations under the sub-Processing contract, where necessary by inspecting the relevant contract documents.

The provisions of this Section 4.f shall mutually apply if the Processor engages a sub-Processor in a country outside the European Economic Area (“EEA”) not recognized by the European Commission as providing an adequate level of protection for personal data.  If, in the performance of this DPA, Fatica Consulting L.L.C. transfers any Personal Data to a sub-processor located outside of the EEA, Fatica Consulting L.L.C. shall, in advance of any such transfer, ensure that a legal mechanism to achieve adequacy in respect of that processing is in place.

h. Data Transfers. Controller acknowledges and agrees that, in connection with the performance of the services under the Agreement, Personal Data will be transferred to Fatica Consulting L.L.C. in the United States.   The Standard Contractual Clauses at Exhibit 1 will apply with respect to Personal Data that is transferred outside the EEA, either directly or via onward transfer, to any country not recognized by the European Commission as providing an adequate level of protection for personal data (as described in the Data Protection Law).

i. Deletion or Retrieval of Personal Data. Other than to the extent required to comply with Data Protection Law, following termination or expiry of the Agreement, Processor will delete all Personal Data (including copies thereof) processed pursuant to this DPA. If Processor is unable to delete Personal Data for technical or other reasons, Processor will apply measures to ensure that Personal Data is blocked from any further Processing.

Controller shall, upon termination or expiration of the Agreement and by way of issuing an Instruction, stipulate, within a period of time set by Processor, the reasonable measures to return data or to delete stored data. Any additional cost arising in connection with the return or deletion of Personal Data after the termination or expiration of the Agreement shall be borne by Controller.

5. Audits

Controller may, prior to the commencement of Processing, and at regular intervals thereafter, audit the technical and organizational measures taken by Processor.

For such purpose, Controller may, e.g.,

• obtain information from the Processor,
• request Processor to submit to Controller an existing attestation or certificate by an independent professional expert, or
• upon reasonable and timely advance agreement, during regular business hours and without interrupting Processor’s business operations, conduct an on-site inspection of Processor’s business operations or have the same conducted by a qualified third party which shall not be a competitor of Processor.

Processor shall, upon Controller’s written request and within a reasonable period of time, provide Controller with all information necessary for such audit, to the extent that such information is within Processor’s control and Processor is not precluded from disclosing it by applicable law, a duty of confidentiality, or any other obligation owed to a third party.

6. General Provisions

With respect to updates and changes to this DPA, the terms that apply in the “Amendment; No Waiver” section of “Miscellaneous” in the Agreement shall apply.

In case of any conflict, this DPA shall take precedence over the regulations of the Agreement. Where individual provisions of this DPA are invalid or unenforceable, the validity and enforceability of the other provisions of this DPA shall not be affected.

Upon the incorporation of this DPA into the Agreement, the parties indicated in Section 7 below (Parties to this DPA) are agreeing to the Standard Contractual Clauses (where and as applicable) and all appendixes attached thereto. In the event of any conflict or inconsistency between this DPA and the Standard Contractual Clauses in Exhibit 1, the Standard Contractual Clauses shall prevail.

Fatica Consulting L.L.C. shall process Personal Data in accordance with the GDPR and other applicable data protection laws in effect at the time of processing.
 
 The obligations under this DPA shall apply to the processing of all Personal Data, regardless of whether such data originates from the EEA, the United Kingdom, Switzerland, or any other jurisdiction with comparable data protection requirements.

7. Parties to this DPA

This DPA is an amendment to and forms part of the Agreement.  Upon the incorporation of this DPA into the Agreement (i) Controller and the Fatica Consulting L.L.C. entity that are each a party to the Agreement are also each a party to this DPA, and (ii) to the extent that Fatica Consulting L.L.C. is not the party to the Agreement, Fatica Consulting L.L.C.. is a party to this DPA, but only with respect to agreement to the Standard Contractual Clauses of the DPA, this Section 7 of the DPA, and to the Standard Contractual Clauses themselves.

If Fatica Consulting L.L.C.is not a party to the Agreement, the section of the Agreement entitled ‘Limitation of Liability’ shall apply as between Controller and Fatica Consulting L.L.C., and in such respect any references to ‘Fatica Consulting L.L.C.’, ‘we’, ‘us’ or ‘our’ shall include both Fatica Consulting L.L.C. and the Fatica Consulting L.L.C. entity that is a party to the Agreement.

The legal entity agreeing to this DPA as Controller represents that it is authorized to agree to and enter into this DPA for, and is agreeing to this DPA solely on behalf of, the Controller.

EXHIBIT 1 – STANDARD CONTRACTUAL CLAUSES (2021)

These Standard Contractual Clauses (the “Clauses”) are incorporated into and form part of the Fatica Consulting L.L.C. Data Processing Agreement (“DPA”), in accordance with Commission Implementing Decision (EU) 2021/914 of 4 June 2021 on standard contractual clauses for the transfer of personal data to third countries under Regulation (EU) 2016/679.

SECTION I – CLAUSES

Clause 1 – Purpose and Scope

(a) These Clauses set out appropriate safeguards, including enforceable data subject rights and effective legal remedies, pursuant to Article 46(1) and Article 46(2)(c) of the GDPR, for the transfer of personal data by the data exporter to the data importer.
 (b) Annex I describes the details of the transfer, including the categories of data, purposes of processing, and identities of the parties.
 (c) These Clauses apply only to the extent the processing involves a transfer of personal data from the EEA, UK, or Switzerland to a third country not recognized as providing an adequate level of protection under applicable Data Protection Law.

Clause 2 – Effect and Hierarchy

These Clauses supplement and prevail over any conflicting terms in the DPA or the Agreement to the extent of the conflict.

Clause 3 – Third-Party Beneficiaries

Data Subjects may invoke and enforce these Clauses as third-party beneficiaries.

Clause 4 – Interpretation

Terms used but not defined herein have the meaning given in the DPA or, if not defined there, in the GDPR.

SECTION II – OBLIGATIONS OF THE PARTIES

Clause 5 – Data Protection Safeguards

1. Processor Obligations.
   The data importer shall process the personal data only on documented instructions from the data exporter, implement appropriate technical and organizational measures as described in Annex II, and assist the data exporter in ensuring compliance with Articles 32–36 GDPR.
2. Confidentiality.
   The data importer ensures that persons authorized to process the personal data have committed themselves to confidentiality.
3. Security.
   The data importer shall implement technical and organizational measures appropriate to the risk, as detailed in Annex II.
4. Sub-processing.
   The data importer may engage sub-processors only with prior specific or general written authorization from the data exporter and under a written contract imposing equivalent obligations. The current list of authorized sub-processors appears in Exhibit 2.
5. Data Subject Rights.
   The data importer shall assist the data exporter in responding to data subject requests under Chapter III GDPR.
6. Personal Data Breaches.
   The data importer shall notify the data exporter without undue delay after becoming aware of a personal data breach affecting data transferred under these Clauses.

Clause 6 – Transfers and Onward Transfers

The data importer shall not onward-transfer the personal data to a third party located outside the EEA unless:
 (a) the third party is bound by these Clauses, the new EU SCCs, or another adequacy mechanism; or
 (b) the data subject has given explicit, informed consent.

Clause 7 – Documentation and Compliance

The data importer shall make available to the data exporter all information necessary to demonstrate compliance with these Clauses and allow audits in accordance with Clause 8 below.

SECTION III – LOCAL LAWS AND OBLIGATIONS AFTER TRANSFER

Clause 8 – Supervisory Authority and Audits

(a) The competent supervisory authority is the one identified in Annex I.C.
 (b) The data importer shall cooperate with supervisory authorities in the performance of their tasks.
 (c) At the request of the data exporter, the data importer shall allow and contribute to audits reasonably necessary to verify compliance with these Clauses.

Clause 9 – Redress

The data importer agrees that data subjects may lodge complaints with the competent supervisory authority or bring proceedings before competent courts in the EEA.

Clause 10 – Governing Law and Jurisdiction

These Clauses shall be governed by the law of the EU Member State where the data exporter is established (or, if not applicable, by Irish law) and subject to the jurisdiction of its courts.

SECTION IV – FINAL PROVISIONS

Clause 11 – Termination

If the data importer cannot comply with these Clauses, it shall inform the data exporter, who may suspend the transfer or terminate the DPA insofar as it concerns the processing under these Clauses.

Clause 12 – Signatures

Execution of the Agreement incorporating this DPA constitutes execution of these Clauses.

ANNEX 1 – DETAILS OF THE TRANSFER

A. Parties
 Data Exporter: Customer (“Controller”), as defined in the Agreement.
Data Importer: Fatica Consulting L.L.C., 2025 N Summit Ave Suite 100, Milwaukee, WI 53202, USA.

B. Description of Transfer

• Categories of Data Subjects: Controller’s contacts and other end users, including employees, customers, location managers, leads, and other persons whose data is processed through the MetaLocator Service.
• Categories of Personal Data: Contact information, geolocation, system usage data, communications data, and any other personal data submitted by the Controller or its end users through the Service.
• Sensitive Data: None anticipated. Controller shall not transfer special categories of data under Article 9 GDPR.
• Frequency of Transfer: Continuous as needed for service provision.
• Purpose of Processing: Provision, maintenance, and support of the MetaLocator Services under the Agreement.
• Duration of Processing: For the term of the Agreement and until deletion of all personal data as provided in the DPA.

C. Competent Supervisory Authority
The supervisory authority in the Member State where the data exporter is established (or the Irish Data Protection Commission if not established in the EEA).

ANNEX 2 – TECHNICAL AND ORGANIZATIONAL MEASURES

Fatica Consulting L.L.C. implements the measures including but not limited to:

1. Access Control: User authentication, role-based access, MFA, and “least privilege” policies.
2. Physical Security: Hosting with SOC 2 and ISO 27001 certified cloud providers.
3. Network Security: Firewalls, intrusion detection, TLS 1.2+ encryption in transit.
4. Data at Rest: Encrypted storage with managed key services using AES-256 encryption.
5. Incident Response: 24/7 monitoring, documented breach notification procedure.
6. Business Continuity: Regular backups, redundancy, and disaster-recovery planning.
7. Personnel Security: Confidentiality agreements and periodic security training.

ANNEX 3 – AUTHORIZED SUB-PROCESSORS

As listed in Exhibit 2 of the DPA (e.g., Amazon Web Services, Google, Twilio, etc.).
 The data importer shall inform the data exporter of any intended addition or replacement of sub-processors and provide an opportunity to object within 30 days.

UK AND SWISS ADDENDA

If the transfer includes data originating from the United Kingdom or Switzerland, the Clauses shall be deemed amended as follows:

For data transfers subject to the Swiss Federal Act on Data Protection, references in the Clauses to the “EU,” “Member State,” and “supervisory authority” shall be interpreted as referring respectively to “Switzerland,” “the Swiss Confederation,” and the “Swiss Federal Data Protection and Information Commissioner (FDPIC).”

EXHIBIT 1A – UK INTERNATIONAL DATA TRANSFER ADDENDUM

(Issued by the Information Commissioner under s.119A(1) Data Protection Act 2018)

This Addendum applies where the transfer of Personal Data is subject to the UK GDPR and the Data Protection Act 2018. It is an addendum to and forms part of the Standard Contractual Clauses (Exhibit 1) incorporated into this DPA.

Part 1 – Tables

Table 1: Parties

Role	Entity	Address	Key Contact
Exporter (Controller)	The Customer (“Controller”) as defined in the Agreement	As stated in the Agreement	Controller’s nominated contact
Importer (Processor)	Fatica Consulting L.L.C.	2025 N Summit Ave Suite 100, Milwaukee, WI 53202 USA	privacy@metalocator.com

Table 2: Selected SCCs, Modules and Clauses

• The parties agree the EU Standard Contractual Clauses incorporated in Exhibit 1 (2021) form the basis of this Addendum.
• The parties agree that execution of this DPA constitutes execution of the UK International Data Transfer Addendum without further action.
• Module Two (Controller → Processor) applies.
• The EU SCCs are governed by Irish law for purposes of Clause 17, and disputes shall be subject to the courts of Ireland under Clause 18.

Table 3: Appendix Information

• Annex I, II and III of the EU SCCs (Exhibit 1) form the Appendices to this Addendum.
• Any references in those Annexes to “Member State” or “Supervisory Authority” shall be read, for UK transfers, as references to the United Kingdom and the Information Commissioner’s Office respectively.

Table 4: Ending this Addendum when the Approved SCCs change

If the European Commission issues new SCCs or the ICO issues a revised UK addendum, the parties agree that the Importer may propose to replace this Addendum with an updated version consistent with UK law. Unless the Exporter objects within 30 days of notice, the replacement will take effect automatically.

Part 2 – Mandatory Clauses

The mandatory clauses set out in Part 2 of the UK International Data Transfer Addendum, Version B.1.0, issued by the ICO on 21 March 2022, are incorporated by reference and form part of this Addendum.

Part 3 – Interpretation

1. Terms defined in the EU SCCs have the same meaning in this Addendum.
2. References to “EU GDPR” shall include the UK GDPR; references to “supervisory authority” shall mean the Information Commissioner.
3. Any conflict between this Addendum and the EU SCCs shall be resolved in favor of this Addendum, insofar as necessary to ensure compliance with the UK GDPR.

Part 4 – Execution

Execution of the Agreement and DPA incorporating this Addendum constitutes execution of this UK Addendum by both parties.

EXHIBIT 2

List of Sub-Processors and purpose.  MetaLocator leverages the Standard Contractual Clauses with each entity below.   Processing location is in the same country as the address below, unless otherwise noted. The current list of sub-processors is available on request or at trust.metalocator.com. Fatica Consulting L.L.C. may update this list from time to time in accordance with Section 4(f).

• Amazon Web Services, Inc.
  • Global Web Hosting,
  • 410 Terry Avenue North, Seattle, WA 98109-5210, United States
• Google, Inc.
  • Global Location Services
  • 1600 Amphitheatre Parkway Mountain View, CA 94043, United States
• Sucuri, Inc.
  • Web Application Firewall
  •  14455 N Hayden Rd Ste 219, Scottsdale, Arizona, 85260, United States
• Twilio, Inc.
  • SMS and IVR Services
  • 101 Spear Street, Fifth Floor, San Francisco, CA, United States
• Drip, Inc.
  • Marketing Automation
  • 251 N 1st Ave #400, Minneapolis, MN, United States,
• Asana
  • Project Management
  • 633 Folsom St, San Francisco, CA 94107, United States
• MapTiler, Inc.
  • Global Location Services
  • 98 Höfnerstrasse, Unterageri, Zug, 6314, Switzerland
• MapBox, Inc
  • Global Location Services
  • 740 15th St NW Fl 5, Washington, District of Columbia, 20005, United States
• Intercom, Inc.
  • Technical Support
  • 55 2nd Street, 4th Floor, San Francisco, CA, United States

IN WITNESS WHEREOF, the parties agree to the terms of this Data Processing Agreement and its Exhibits.
 Execution of the Agreement or any Order Form referencing this DPA constitutes execution of this DPA by both parties.

For the Customer (Controller)	For Fatica Consulting L.L.C. (Processor)
Name: ___________________________	Name: Michael Fatica
Title: __________________________	Title: Chief Executive Officer
Company: _______________________	Company: Fatica Consulting L.L.C.
Address: _______________________	Address: 2025 N Summit Ave Suite 100, Milwaukee, WI 53202 USA
Signature: _____________________	Signature: _____________________
Date: __________________________	Date: __________________________