1. List Of Parties Data exporter(s): ( if applicable ) Name: Address: Contact person’s name, position and contact details: Role (controller/processor): Controller Data importer(s): Name: RELAYTO LIMITED Registered Address: 131 Continental Drive, Suite 301, Newark, DE 19713-4323, United States Contact person’s name, position and contact details: Alex Shevelenko support @relayto.com Role (controller/processor): Processor 2. Description Of Transfer Categories of data subjects whose personal data is transferred: Employees and collaborators of the Controller Categories of personal data transferred: account identifiers (name, email), professional contact details, authentication data, usage and device data, and any personal data Customer or End Users upload into Stored Data Sensitive data is not required to use the Services. Customer must not upload special-category data or PHI unless the parties have signed a separate agreement covering that data (a BAA for PHI, available on request). After a BAA is signed, the recommended method for PHI-adjacent material is to run AI generation on placeholders or de-identified content first, then add PHI manually in the RELAYTO AI editor so that PHI is not sent to a model provider. The frequency of the transfer (e.g. whether the data is transferred on a one-off or continuous basis): Continuous The period for which the personal data will be retained, or, if that is not possible, the criteria used to determine that period: Account Data and Stored Data for the Term plus at least 30 days after termination (then deletion, subject to legal hold and backup expiry). Analytics logs are retained for the Term unless the Order Form states a longer period. 3. 3. Competent Supervisory Authority (Annex I.C): the Irish Data Protection Commission, unless the data exporter is established in another EU Member State, in which case that Member State's supervisory authority applies. ANNEX II Technical And Organizational Measures Including Technical And Organizational Measures To Ensure The Security Of The Data 36 of 53
Relayto Terms, Conditions, Policies & Plans Page 35 Page 37