Data Processing Agreement

Last Modified: June 22, 2025

Eventur, Inc. Data Processing Agreement

This Eventur, Inc. Data Processing Agreement (“DPA”) and its Annexes, reflects the parties’ agreement with respect to (i) the Processing of Customer Personal Data by Eventur, Inc. as a Processor on the Customers behalf, and (ii) the Processing of Controller Personal Data by each party in connection with the Eventur, Inc. products: Eventur Conference, Eventur Online Registration, Eventur Virtual Hub, Eventur Mobile Event App, Eventur Event Kiosk App and Eventur CE Webinar Link(Subscription Services).

The Processor terms apply solely to the extent that Eventur, Inc. is a Processor of Customer Personal Data in connection with Subscription Services.

The Controller terms apply solely to the extent that the Customer uses the Eventur, Inc. Products (Subscription Services) and each party is considered a Controller under Data Protection Laws.

We update these terms from time to time. If you have an active Eventur, Inc. Subscription Service, we will let you know when we do by email.

The term of this DPA will follow the terms of the Eventur Event Agreement. Terms not otherwise defined in this DPA will have the meaning as set forth in the Eventur Event Agreement.

1. DEFINITIONS

“California Personal Information” means Customer 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 Processing Personal Data.

“Controller Personal Data” means Personal Data that each party Processes as a Controller in connection with the products or the Eventur, Inc. Subscription Services, and each party is considered a Controller under Data Protection Laws.

“Customer Personal Data” means Personal Data contained within Customer Data that Eventur, Inc. Processes as a Processor on behalf of Customer.

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

“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 legislation relating to data protection and privacy which applies to the Processing of Personal Data under the Eventur Event Agreement.

“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 Customer 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 parts 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 Customer to Eventur, Inc., and directing Eventur, Inc. to perform a specific or general action with regard to Customer Personal Data (including, but not limited to, depersonalizing, blocking, deletion, and making available).

“Permitted Affiliates” means any of your Affiliates that (i) are permitted to use the Subscription Services pursuant to the Eventur Event Agreement but have not signed their own separate Eventur Event Agreement with us and are not a “Customer” as defined under the Eventur Event Agreement, (ii) qualify as a Controller of Customer Personal Data or Controller Personal Data.

“Personal Data” means any information relating to an identified or identifiable individual where such information is protected similarly as personal data, personal information, or personally identifiable information under Data Protection Laws and outlined in the Eventur Privacy Policy. https://www.eventur.com/privacy-policy/

“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.

“Restricted Transfer” means transfer of Personal Data originating from Europe to a country that does not provide an adequate level of protection within the meaning of applicable European Data Protection Laws.

“Standard Contractual Clauses” means the standard contractual clauses for the transfer of personal data to third countries adopted by the European Commission’s Implementing Decision 2021/914 of 4 June 2021

“Sub-Processor” means any Processor engaged by us or our Affiliates to assist in fulfilling our obligations with respect to the Processing of Customer Personal Data under the Eventur Event Agreement. Sub-Processors will exclude any Eventur, Inc. 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.

2. CUSTOMER RESPONSIBILITIES

2.1. Compliance with Laws. Within the scope of the Eventur Event Agreement and your use of the Subscription Services, you will be responsible for complying with all requirements that apply to you under Data Protection Laws with respect to your Processing of Personal Data.

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 Personal Data and the means by which you acquired such data; (ii) complying with all necessary transparency and lawfulness requirements under Data Protection Laws for the collection and use of Customer Personal Data, including providing adequate notices, obtaining any necessary consents and authorizations, and honoring opt-out preferences (particularly for use by Customer for marketing purposes); (iii) ensuring you have the right to transfer, or provide access to, the Customer Personal Data to us for Processing in accordance with the terms of the Eventur Event Agreement (including this DPA); (iv) complying with all laws applicable to any emails or other content created, sent, or managed through the Subscription Services (including those relating to obtaining consents to send emails, the content of emails, and email deployment practices); and (v) ensuring that your use of Controller Personal Data complies with Data Protection Laws and is strictly limited to the purposes set out in the Eventur Event Agreement (including this DPA). You will inform us without undue delay if you are not able to comply with your responsibilities under this ‘Compliance with Laws’ section or Data Protection Laws.

2.2 Customer Instructions. You are responsible for ensuring that your Instructions to us regarding the Processing of Customer Personal Data comply with applicable laws, including Data Protection Laws. The parties agree that the Eventur Event Agreement (including this DPA), together with your use of the Subscription Service in accordance with the Eventur EULA and Eventur Privacy Policy, constitute your complete Instructions to us in relation to Eventur, Inc.’s Processing of Customer Personal Data.

2.3 Security. You are responsible for independently determining whether the data security provided for in the Subscription Service adequately meets your obligations under 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 such data).

3. EVENTUR, INC. OBLIGATIONS AS PROCESSOR

3.1 Compliance with Instructions. We will only Process Customer Personal Data for the purposes described in this DPA or as otherwise agreed within the scope of the Subscription Service. We are not responsible for compliance with any Data Protection Laws applicable to you or your industry that are not generally applicable to us.

3.2 Conflict of Laws. If we become aware that we cannot Process Customer 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 Customer 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 Eventur Event Agreement for any failure to perform the applicable Subscription Services until such time as you issue new lawful Instructions with regard to the Processing.

3.3 Security. We will implement and maintain appropriate technical and organizational measures to protect Customer Personal Data from Customer Personal Data Breaches, as described in this DPA and 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.

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

3.5 Customer Personal Data Breaches. We will notify you without undue delay after we become aware of any Customer Personal Data Breach and will provide timely information relating to the Customer Personal Data Breach as it becomes known or reasonably requested by you. At your request, we will promptly provide you with such reasonable assistance as necessary to enable you to notify relevant Customer Personal Data Breaches to competent authorities and/or affected Data Subjects, if you are required to do so under Data Protection Laws.

3.6 Deletion or Return of Customer Personal Data. We will delete, return or make available all Customer Data, including Customer Personal Data (including copies thereof) Processed pursuant to this DPA, on termination or expiration of your Subscription Service. This may be at a cost to the customer. 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.

If you need help retrieving your Customer Data during the Subscription Term, we will provide reasonable assistance to you, at your cost, and in accordance with the Event Eventur Event Agreement. We will notify you in advance of any applicable costs which will be commercially reasonable.

You may request the deletion of your Eventur, Inc. account after expiration or termination of your subscription by contacting Eventur, Inc. via email or written request sent to the Eventur, Inc address.

We strongly recommend retrieving your Customer Data prior to the end of your Subscription Term.

3.7 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 ensure redundancy and fail-over protections during a significant processing failure. Customer data is backed up to multiple durable data stores and replicated across multiple availability zones.

Online replicas and backups: Where feasible, production databases are designed to replicate data between no less than 1 primary and 1 secondary instance. All databases are backed up and maintained using at least industry standard methods.

Disaster Recovery Plans: We maintain and regularly test disaster recovery plans to help ensure availability of information following interruption to, or failure of, critical business processes.

Our products are designed to ensure redundancy and seamless failover. The server instances that support the products are also architected with a goal to prevent single points of failure. This design assists our operations in maintaining and updating the product applications while limiting downtime.

4. DATA SUBJECT REQUESTS

The Subscription Service provides you with a number of controls that you can use to retrieve, correct, delete, or restrict Customer 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 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 Customer Personal Data under the Eventur Event Agreement. You will reimburse us for the commercially reasonable costs arising from this assistance, and we will notify you of these costs in advance.

If a Data Subject Request or other communication regarding the Processing of Customer Personal Data under the Eventur Event 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 Customer Personal Data.

5. SUB-PROCESSORS

You agree we may engage Sub-Processors to Process Customer Personal Data on your behalf, and we do so by engaging Sub-Processors to assist us with hosting and infrastructure.

We have currently appointed, as Sub-Processor, Microsoft, Inc.

We will give you the opportunity to object to the engagement of new Sub-Processors on reasonable grounds relating to the protection of Customer 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 Eventur Event 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 Customer 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 Customer Personal Data as necessary to provide the Subscription Service in accordance with the DPA, and in particular that Customer Personal Data may be transferred to and Processed by Eventur, Inc. in the United States.

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 ‘Demonstration of Compliance’ 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). Upon request, we will supply (on a confidential basis) our 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 noncompliance with the DPA.

8. ADDITIONAL PROVISIONS FOR EUROPEAN DATA

8.1 Scope. This ‘Additional Provisions for European Data’ section will apply only with respect to European Data that Eventur, Inc. Processes on your behalf under the Agreement.

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

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

8.4 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 (for example, the French Data Protection Agency (CNIL), the Berlin Data Protection Authority (BlnBDI) and the UK Information Commissioner’s Office (ICO)) or other competent data privacy authorities to the extent required by European Data Protection Laws.

8.5 Data Transfers. Eventur, Inc. will not transfer European Data to any country or recipient not recognized as providing an adequate level of protection for Customer 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 Customer 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.

9. ADDITIONAL PROVISIONS FOR CALIFORNIA PERSONAL INFORMATION

9.1 Scope. The ‘Additional Provisions for California Personal Information’ section of the DPA will apply only with respect to California Personal Information that Eventur, Inc. Processes on your behalf under the Eventur Event Agreement.

9.2 Role of 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.

9.3 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 Eventur Event 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 that we will not (i) Sell or Share California Personal Information; (ii) Process California Personal Information outside the direct business relationship between the parties, unless required by applicable law; or (iii) combine California Personal Information included in Customer Data with Personal Data 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 Eventur Event Agreement).

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

9.5 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 Eventur Event Agreement to stop and remediate unauthorized use of California Personal Information.

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

10. GENERAL PROVISIONS

10.1 Amendments. Notwithstanding anything else to the contrary in the Eventur Event Agreement and without prejudice to the ‘Compliance with Instructions’ or ‘Security’ sections of this DPA, we reserve the right to make any updates and changes to this DPA and the terms that apply in the Eventur Event Agreement.

10.2 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.

10.3 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 data processing agreements 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 the ‘Limitation of Liability’ section of the Eventur Event Agreement and any reference in such section to the liability of a party means aggregate liability of that party and all of its Affiliates under the Eventur Event Agreement (including this DPA).

10.4 Governing Law. This DPA will be governed by and construed in accordance with Colorado State Laws, unless required otherwise by Data Protection Laws.

10.5 Termination. This agreement is terminated based on the term of the Eventur Event Agreement.

11. PARTIES TO THIS DPA

11.1 Permitted Affiliates. By signing the Eventur Event Agreement and this DPA, you enter into this DPA 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.

11.2 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.

11.3 Remedies. The parties agree that (i) solely the Customer entity that is the contracting party to the Eventur Event Agreement will exercise any right or seek any remedy under this DPA on behalf of its Affiliates, and (ii) the Customer entity that is the contracting party to the Eventur Event 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.

ANNEX 1A

DETAILS OF PROCESSING – EVENTUR, INC. AS PROCESSOR

LIST OF PARTIES

Data exporter:

Name: The Customer, as defined in the Eventur Event Agreement (on behalf of itself and Permitted Affiliates)

Address: The Customer’s address, as set out in the Eventur Event Agreement

Contact person’s name, position and contact details: The Customer’s contact details, as set out in the Eventur Event Agreement and/or as set out in the Customer’s Eventur, Inc. account

Activities relevant to the data transferred under these Clauses: Processing of Customer Personal Data in connection with Customer’s use of the Eventur, Inc. Subscription Services under the Eventur, Inc. Customer Terms of Service

Role: Processor

Data importer:

Name: Eventur, Inc.

Address: 585 IAN CT, Castle Pines, CO 80108, USA

Contact person’s name, position and contact details: Luke Jimmink, Data Protection Officer, Eventur, Inc. 585 IAN CT, Castle Pines, CO 80108, USA

Activities relevant to the data transferred under these Clauses: Processing of Customer Personal Data in connection with Customer’s use of the Eventur, Inc. Subscription Service.

Role: Processor

DESCRIPTION OF TRANSFER
Categories of Data Subjects whose Personal Data is Transferred

You may submit Customer 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 Customer Personal Data relating to the following categories of Data Subjects:

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 of Personal Data:

Contact Information (as defined in the Eventur Privacy Policy).
2. Any other Personal Data submitted by, sent to, or received by you, or your end users, via the Subscription Service.

Sensitive Data Transferred and Applied Restrictions or Safeguards
The processing of Sensitive Data is subject to the scope limitations, restrictions, and safeguards mutually agreed upon by the parties, as reflected in Eventur Inc., Event Agreement, Privacy Policy and EULA.

Frequency of the Transfer
Continuous

Nature of the Processing
Customer Personal Data will be Processed in accordance with the Eventur Event Agreement (including this DPA) and may be subject to the following Processing activities:

Storage and other Processing necessary to provide, maintain and improve the Subscription Services provided to you; and/or
Disclosure in accordance with the Eventur Event Agreement (including this DPA) and/or as compelled by applicable laws.

Purpose of the Transfer and Further Processing

We will Process Customer Personal Data as necessary to provide the Subscription Services pursuant to the Agreement, as further specified in the Eventur Event Agreement.

Period for which Personal Data will be retained

Subject to the ‘Deletion or Return of Customer Personal Data’ section of this DPA, we will Process Customer Personal Data for the duration of the Eventur Event Agreement, unless otherwise agreed in writing.

ANNEX 1B

CONTROLLER TO CONTROLLER

DETAILS OF PROCESSING – CUSTOMER AS CONTROLLER

LIST OF PARTIES
Data exporter/importer: Customer

Name: The Customer, as defined in the Eventur Event Agreement (on behalf of itself and Permitted Affiliates)

Address: The Customer’s address, as set out in the Eventur Event Agreement

Contact person’s name, position, and contact details, including email: The Customer’s contact details, as set out in the Order Form and/or as set out in the Eventur Event Agreement

Activities relevant to the data transferred under these Clauses: Processing of Controller Personal Data in connection with Customer’s use of the Subscription Services

Role (controller/processor): Controller

Data exporter/importer: Eventur, Inc.

Name: Eventur, Inc.

Address: 585 Ian Ct, Castle Pines, CO 80108, USA

Contact person’s name, position, and contact details: Luke Jimmink, Data Protection Officer, Eventur, Inc., 585 Ian Ct, Castle Pines, CO 80108, USA

Activities relevant to the data transferred under these Clauses: Processing of Controller Personal Data in connection with Customer’s use of the Subscription Services

Role (controller/processor): Controller

DESCRIPTION OF TRANSFER

Categories of Data Subjects whose Personal Data is Transferred
Individuals associated with a company or other institution

Categories of Personal Data Transferred
Professional data, which may include, but is not limited to, first and last name, business email address, , and other similar information

Sensitive Data Transferred and Applied Restrictions or Safeguards
The parties do not anticipate the transfer of sensitive data.

Frequency of the Transfer
Continuous

Nature of the Processing
Customer Personal Data will be Processed in accordance with the Eventur Event Agreement (including this DPA) and may be subject to the following Processing activities:

Storage and other Processing necessary to provide, maintain and improve the Subscription Services provided to you; and/or
Disclosure in accordance with the Eventur Event Agreement (including this DPA) and/or as compelled by applicable laws.

Purpose of the Transfer and Further Processing

We will Process Customer Personal Data as necessary to provide the Subscription Services pursuant to the Agreement, as further specified in the Eventur Event Agreement.

Period for which Personal Data will be retained

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 as set forth in the Eventur Event Agreement, Privacy Policy and EULA.

INFORMATION SECURITY POLICY

We maintain and adhere to an internal, written Information Security Policy.

ACCESS CONTROL

2.1 Preventing Unauthorized Product Access. 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 multi-tenant, outsourced infrastructure providers. We do not own or maintain hardware located at the outsourced infrastructure providers’ data centers. Production servers and client-facing applications are logically and physically secured from our internal corporate information systems. The infrastructure providers’ physical and environmental security controls are audited for SOC 2 Type II and ISO 27001 compliance, among other certifications.

Authentication: We implement a password policy for our customer products. Customers who interact with the products via the user interface must authenticate before accessing Customer Personal Data in their Eventur, Inc. account.

Authorization: Customer Data is stored in multi-tenant storage systems accessible to Customers via only application user interfaces and application programming interfaces. Customers are not allowed direct access to the underlying application infrastructure. The authorization model in each of our products is designed to ensure that only the appropriately assigned individuals can access relevant features, views, and customization options. Authorization to data sets is performed through validating the user’s permissions against the attributes associated with each data set.

2.2 Preventing Unauthorized Product Use. We implement industry standard access controls and detection capabilities for the internal networks that support its products.

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 Virtual Private Cloud (VPC) implementations, security group assignment, and traditional 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.

Endpoint Harding: Endpoints are hardened in accordance with industry standard practice. Workstations are protected using anti-malware and endpoint detection & response tools, receiving regular definition and signature updates.

TRANSMISSION CONTROL

In-transit: We require HTTPS encryption (also referred to as SSL or TLS) on all login interfaces to the Subscription Services. Our HTTPS implementation uses industry standard algorithms and certificates.

At-rest: We store user passwords following policies that follow industry standard practices for security. We take a layered approach of at-rest encryption technologies to ensure Customer Data and Customer-identified Permitted Sensitive Data are appropriately encrypted.

INCIDENT MANAGEMENT, LOGGING, AND MONITORING

Incident Response Plan: We maintain a written Incident Response Plan, playbooks, and other necessary processes and procedures to fulfill the standards and obligations reflected therein.

Detection: We designed our infrastructure to log extensive information about the system behavior, traffic received, system authentication, and other application requests. Internal systems aggregate log data and alert appropriate employees of malicious, unintended, or anomalous activities. Our personnel, including security, operations, and support 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 terms of this Agreement.

VULNERABILITY MANAGEMENT PROGRAM

Vulnerability Remediation Schedule: We maintain a vulnerability remediation schedule aligned with industry standards. We take a risk-based approach to determining a vulnerability’s applicability, likelihood, and impact in our environment.

Vulnerability scanning: We perform periodic vulnerability scanning on our products using technology and detection standards aligned with industry standards.

Penetration testing: We maintain relationships with industry-recognized penetration testing service providers for penetration testing of both the Eventur, Inc. web application and internal corporate network infrastructure at least annually. 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.

PERSONNEL MANAGEMENT

We staff qualified personnel to develop, maintain, and enhance our security program. We train all employees on security policy, processes, and standards relevant to their role and in accordance with industry practice.

Background checks: Where permitted by applicable law, Eventur, Inc. 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 Eventur, Inc. employees are required to conduct themselves in a manner consistent with company guidelines, non-disclosure requirements, and ethical standards.

Privacy Statement Update Notes (July 22, 2025):

Updated entire agreement