For an executable copy, please reach out to [email protected]

This Data Processing Addendum (“DPA”) forms part of the Terms of Service or Master Services Agreement (or other similarly titled written or electronic agreement addressing the same subject matter) (“Agreement”) between Customer (as defined in the Agreement) and Unduit (“Processor”) under which the Processor provides the Controller with the software and services (the “Services”). The Controller and the Processor are individually referred to as a “Party” and collectively as the “Parties.”

The Parties seek to implement this DPA to comply with the requirements of applicable Data Protection Laws (defined hereunder) in relation to Processor’s processing of Data as part of its obligations under the Agreement.

This DPA shall apply to Processor’s processing of Data, provided by the Controller as part of Processor’s obligations under the Agreement.

This DPA replaces and supersedes any data processing agreement or data protection addendum previously executed between the Parties with respect to the subject matter hereof. Except as modified below, the terms of the Agreement shall remain in full force and effect.

1. Definitions

Terms not otherwise defined herein shall have the meaning given to them in the applicable Data Protection Laws or the Agreement. The following terms shall have the corresponding meanings assigned to them below:

1.1. “Data” means the categories of data as described in Annex I to Schedule 1 of this DPA, which may include personal data as described.

1.1.1. “Data Transfer” means a transfer of the Data from the Controller to the Processor, or between two establishments of the Processor, or with a Sub-processor by the Processor.

1.2. “EU GDPR” means the EU General Data Protection Regulation, as amended or replaced from time to time.

1.3. “UK GDPR” means the UK General Data Protection Regulation and the UK Data Protection Act, as amended or replaced from time to time.

1.4. “Data Protection Laws” means the EU GDPR, the UK GDPR, the California Consumer Privacy Act as amended by the California Privacy Rights Act (“CCPA”), and any other data protection or privacy law that applies to the processing of Data under the Agreement.

1.5. “Services” means the services provided by Unduit to Customer as defined in the Agreement.

1.6. “Standard Contractual Clauses” means the standard contractual clauses for the transfer of personal data to third countries approved by the European Commission, as amended or replaced from time to time, incorporated by reference under Section 10, the Annexes to which are set out in Schedule 1.

1.7. “UK International Data Transfer Addendum” means the international data transfer addendum to the Standard Contractual Clauses issued by the UK Information Commissioner, as amended or replaced from time to time.

1.8. “Controller” means the legal entity that determines the purposes and means of the processing of Data. For the purposes of this DPA, Customer is the Controller.

1.9. “Processor” means the legal entity that processes Data on behalf of the Controller in accordance with the permissions in this DPA. For the purposes of this DPA, Unduit is the Processor and processes Data solely for the purpose of providing the Services under the applicable agreement.

1.10. “Sub-processor” means a processor/sub-contractor appointed by the Processor for the provision of all or parts of the Services including the processing of Data as provided by the Controller.

1.11. “Data Subject” means an identified or identifiable natural person to whom the Data relates.

2. Purpose of this DPA

This DPA sets out various obligations of the Processor in relation to the Processing of Data and shall be limited to the Processor’s obligations under the Agreement. If there is a conflict between the provisions of the Agreement and this DPA, the provisions of this DPA shall prevail. If there is a conflict between this DPA and the Standard Contractual Clauses or the UK International Data Transfer Addendum, the Standard Contractual Clauses or the UK International Data Transfer Addendum prevail to the extent of the conflict.

3. Permissions and Categories of Data 

The Controller authorizes permission to the Processor to process the Data to the extent of which is determined and regulated by the Controller. The current nature of the Data is specified in Annex I to Schedule 1 to this DPA.

4. Purpose of Processing

The objective of Processing of Data by the Processor shall be limited to the Processor’s provision of the Services to the Controller, pursuant to the Agreement (“Processing”).

5. Duration of Processing

The Processor will Process Data for the duration of the Agreement, unless otherwise agreed upon in writing by the Controller.

6. Controller’s Obligations

6.1. The Controller warrants that it has all necessary rights to provide the Data to the Processor for the Processing to be performed in relation to the agreed services. To the extent required by Data Protection Laws, Controller is responsible for ensuring that it provides such Data to Processor based on an appropriate legal basis allowing lawful processing activities, including any necessary Data Subject consents to this Processing are obtained, and for ensuring that a record of such consents is maintained. Should such consent be revoked by the Data Subject, the Controller is responsible for communicating the fact of such revocation to the Processor.

6.2. The Controller shall provide all natural persons from whom it collects Data with the relevant privacy notice.

6.3. The Controller shall request the Processor to purge Data when required by the Controller or any Data Subject from whom it collects Data, unless the Processor is otherwise required to retain the Data by applicable law.

6.4. The Controller shall immediately advise the Processor in writing if it receives or learns of any:

6.4.1. Complaint or allegation indicating a violation of Data Protection Laws regarding Data;

6.4.2. Request from one or more individuals seeking to access, correct, or delete Data;

6.4.3. Inquiry or complaint from one or more individuals relating to the collection, processing, use, or transfer of Data; and

6.4.4. Any regulatory request, search warrant, or other legal, regulatory, administrative, or governmental process seeking Data.

7. Processor’s Obligations

7.1. The Processor shall process Data only on documented instructions from the Controller’s authorized personnel as specified in the Agreement or as otherwise designated in writing by the Controller. The Controller ensures that any instructions provided to the Processor comply with all applicable Data Protection Laws.

7.2. The Processing described in the Agreement and the relating documentation shall be considered as Instruction from the Controller.

7.3. At the Controller’s request, the Processor will provide reasonable assistance to the Controller in responding to/complying with requests/directions by Data Subjects in exercising their rights or of the applicable regulatory authorities regarding Processor’s Processing of Data.

7.4. The Controller shall be responsible for obtaining consent (where necessary) and/or providing notice to the Data Subject in accordance with Data Protection Laws. The Processor shall provide reasonable assistance to the Controller in fulfilling these obligations where such assistance relates to the Processor’s processing activities under the Agreement.

7.5. Where Data is transferred outside the Processor’s territorial boundaries, the transferor shall ensure that the recipient of such data is under contractual obligations to protect such Data to the same or higher standards as those imposed under this DPA and the Data Protection Laws.

7.6. The Processor shall inform the Controller if, in its opinion, a processing instruction infringes applicable legislation or regulation.

7.7. As a Processor, taking into account the nature of the processing and the information available to the Processor, the Processor shall assist the Controller in conducting any necessary Data Protection Impact Assessments (DPIAs), as required under applicable Data Protection Laws.

8. Confidentiality

8.1. To Process the Data, the Processor will use personnel who are:

8.1.1. Informed of the confidential nature of the Data, and

8.1.2. Perform the Services in accordance with the Agreement.

8.2. The Processor will regularly train individuals having access to Data in data security and data privacy in accordance with accepted industry practice and shall ensure that all the Data is kept strictly confidential.

8.3. The Processor will maintain appropriate technical and organizational measures for protection of the security, confidentiality, and integrity of the Data, including the measures set out in Annex II of Schedule 1.

9. Audit Rights

9.1. Upon the Controller’s reasonable request, the Processor will make available to the Controller, information as is reasonably necessary to demonstrate Processor’s compliance with its obligations under applicable Data Protection Laws in respect of its Processing of the Data.

9.2. The Processor may satisfy audit requests by providing its most recent SOC 2 Type II report and ISO/IEC 27001 certificate. Where these are insufficient to demonstrate compliance, or where required by a supervisory authority, the Controller may conduct an audit (by itself or through a representative) at the Processor’s site no more than once per year, on at least thirty (30) days’ prior written notice. The Processor will provide reasonable cooperation and assistance in relation to such audits.

9.3. The Controller shall bear the expense of such an audit.

10. Mechanism of Data Transfers

10.1. Any Data Transfer for the purpose of Processing by the Processor in a country outside the European Economic Area (the “EEA”) or the United Kingdom shall only take place in compliance as detailed in Schedule 1 to the DPA. For transfers from the EEA, the Standard Contractual Clauses shall apply. For transfers from the United Kingdom, the UK International Data Transfer Addendum shall apply. 

10.2. By entering into the Agreement, including by accepting the Terms of Service, the Controller is deemed to have executed the Standard Contractual Clauses (Module 2: Controller to Processor) and, where applicable, the UK International Data Transfer Addendum, which are incorporated herein by reference. For the purposes of the Standard Contractual Clauses: (a) Clause 7 (docking clause) does not apply; (b) in Clause 9, Option 2 (general written authorisation) applies, with the notice period set out in Section 11 of this DPA; (c) in Clause 11, the optional language does not apply; (d) in Clause 17, the Standard Contractual Clauses are governed by the laws of Ireland; and (e) in Clause 18, disputes are resolved by the courts of Ireland. For the UK International Data Transfer Addendum, the parties, selected clauses and appendix information are as set out in this DPA and Schedule 1, and either party may end the Addendum as set out in its Section 19. The Annexes to this DPA (Annex I, II, and III) shall serve as the corresponding annexes to the Standard Contractual Clauses. The full text of the Standard Contractual Clauses and the UK International Data Transfer Addendum is available upon request from [email protected].

11. Sub-processors

11.1. The Controller hereby authorizes the Processor to engage Sub-processors to Process Data in connection with the Services, provided each Sub-processor is bound to data protection terms no less protective than this DPA. A list of all Sub-processors is available at Unduit’s Trust Center at trust.unduit.com (the “Sub-processor List”). Sub-processor List may be amended from time to time. The Processor will notify the Controller every time a new Sub-processor is added. Subject to Section 11.3, each new Sub-processor may begin Processing Data on or after the tenth (10th) day following notice, during which the Controller may object under Section 11.2. The Processor remains responsible to the Controller for the performance of each Sub-processor’s obligations under this DPA.

11.2. If the Controller has a reasonable, good-faith basis relating to data protection to object to a Sub-processor, it shall notify the Processor in writing within the ten (10) day period in Section 11.1. The Parties shall confer in good faith, and the Processor may (a) decline to engage that Sub-processor for the Controller’s Data, (b) take corrective steps, or (c) recommend a commercially reasonable change to avoid such Processing. If unresolved within a reasonable period, the Controller’s sole remedy is to terminate, on written notice, the portion of the Services that cannot be provided without the objected-to Sub-processor, in accordance with the Agreement.

11.2.1. Section 11.2 does not apply to a Sub-processor the Processor engages to perform Services, or provide services in a location, requested or initiated by the Controller. In such cases the Processor will use reasonable efforts to offer an alternative, and where none is available, the Controller’s remedy is to withdraw the request.

11.3. Notwithstanding Section 11.1, the Processor may engage or replace a Sub-processor without advance notice where urgent and outside its reasonable control. The Processor shall update the Sub-processor List as soon as reasonably practicable thereafter, and the Controller retains its right to object under Section 11.2.

12. Data Breach Notification

12.1. The Processor shall maintain defined procedures in case of a Data Breach (as defined under the GDPR) and shall notify the Controller without undue delay, and in any event within forty-eight (48) hours, after becoming aware of any Data Breach affecting Data Processed under this DPA.

12.2. The Processor shall provide the Controller with all reasonable assistance to comply with the notification of Data Breach to the Supervisory Authority and/or the Data Subject, to identify the cause of such Data Breach and take such commercially reasonable steps as reasonably required to mitigate and remedy such Data Breach.

12.3. No Acknowledgement of Fault by Processor. Processor’s notification of or response to a Data Breach under this DPA will not be construed as an acknowledgement by Processor of any fault or liability with respect to the data incident.

13. Return and Deletion of Data

13.1. Upon the end of the Agreement or cessation of the Processor’s Services under the Agreement, whichever occurs earlier, the Processor shall return to the Controller all the Data, or if the Controller so instructs, the Processor shall have the Data deleted. The Processor shall return such Data in a commonly used format or in the current format in which it was stored at the discretion of the Controller, as soon as reasonably practicable following receipt of Controller’s notification.

13.2. The Processor shall delete the Data, including all copies, when it no longer has a legitimate business or legal basis to retain it, unless retention is required by applicable law. Where Data is held in secure, automated backup or disaster-recovery archives from which deletion is not immediately practicable, the Processor will isolate such data from active processing and delete it in the ordinary course of its backup cycle.

14. Technical and Organizational Measures

Having regard to the state of technological development and the cost of implementing any measures, the Processor will take appropriate technical and organizational measures against the unauthorized or unlawful processing of Data and against the accidental loss or destruction of, or damage to, Data to ensure a level of security appropriate to: (a) the harm that might result from unauthorized or unlawful processing or accidental loss, destruction or damage; and (b) the nature of the data to be protected, including the measures stated in Annex II of Schedule 1.

15. Limitation of Liability

15.1. Each Party’s liability arising out of or related to this DPA, whether in contract, tort, or under any other theory of liability, shall be subject to the limitations and exclusions of liability set forth in the Agreement, and any reference in the Agreement to the liability of a Party means the aggregate liability of that Party under both the Agreement and this DPA.

15.2. Nothing in Section 15.1 or in the Agreement limits either Party’s liability to Data Subjects under the third-party beneficiary provisions of the Standard Contractual Clauses or the UK International Data Transfer Addendum, to the extent such limitation is not permitted by Data Protection Laws.

16. Indemnification

16.1. The Controller shall indemnify, defend, and hold harmless the Processor from and against any claims, damages, losses, costs, and expenses (including reasonable legal fees) arising from or in connection with: (a) the Controller’s breach of its obligations under this DPA or applicable Data Protection Laws; (b) any processing instruction provided by the Controller that infringes applicable Data Protection Laws; or (c) any claim by a Data Subject arising from the Controller’s failure to obtain necessary consents or provide required notices.

16.2. The Processor shall indemnify, defend, and hold harmless the Controller from and against any claims, damages, losses, costs, and expenses (including reasonable legal fees) arising from or in connection with the Processor’s breach of its obligations under this DPA, except to the extent caused by the Controller’s breach of Section 6.1 or Section 16.1 of this DPA.

17. CCPA Service Provider Provisions

To the extent that the CCPA applies to the Processing of Data under this DPA:

17.1. The Processor shall act as a “service provider” as defined under the CCPA and shall process Data only for the specific business purposes set forth in the Agreement.

17.2. The Processor shall not sell or share (as those terms are defined under the CCPA) any Data provided by the Controller.

17.3. The Processor shall not retain, use, or disclose Data for any purpose other than for the business purposes specified in the Agreement, including retaining, using, or disclosing Data for a commercial purpose other than providing the Services.

17.4. The Processor shall not combine Data received from the Controller with personal information that it receives from or on behalf of another person or persons, or collects from its own interaction with the consumer, except as expressly permitted by the CCPA.

17.5. The Processor hereby certifies that it understands and will comply with the restrictions set forth in this Section 17.

17.6. The Processor shall provide reasonable assistance to the Controller in responding to verifiable consumer requests under the CCPA.

18. Governing Law and Jurisdiction

This DPA shall be governed by and construed in accordance with the governing law provisions of the Agreement. In the event of any dispute arising out of or in connection with this DPA, the dispute resolution provisions of the Agreement shall apply. Except where the Standard Contractual Clauses incorporated under Section 10 apply, references in this DPA to applicable Data Protection Laws are included solely for compliance purposes and shall not be construed as constituting any submission by either Party to the jurisdiction of any court, supervisory authority, or regulatory body under such Data Protection Laws.

SCHEDULE 1

ANNEX I

A. List of Parties

Data exporter(s): 

• Name: Customer, as set forth in the relevant Order Form or, where there is no Order Form, as provided by the Customer at account registration on the Unduit platform
• Address: As set forth in the relevant Order Form or, where there is no Order Form, as provided by the Customer at account registration
• Contact person’s name, position, and contact details: As set forth in the relevant Order Form or, where there is no Order Form, the account owner or administrator details provided at account registration
• Activities relevant to the data transferred under these Clauses: Recipient of the Services provided by Unduit in accordance with the Agreement
• Signature and date: The Customer’s acceptance of the Agreement, including acceptance of the Terms of Service at account registration, constitutes its signature of this DPA and the Standard Contractual Clauses, effective on the date of such acceptance
• Role (Controller/Processor): Controller

Data importer(s): 

• Name: Unduit LLC
• Address: 5400 Patton Dr Ste 1, Lisle, IL 60532, US
• Contact person’s name, position, and contact details: [email protected]
• Activities relevant to the data transferred under these Clauses: Provision of the Services to the Customer in accordance with the Agreement
• Signature and date: Unduit’s provision of the Services under the Agreement constitutes its signature of this DPA and the Standard Contractual Clauses, effective on the date the Customer accepts the Agreement. Where the Parties execute a copy of this DPA, the signature and date on that executed copy apply.
• Role (Controller/Processor): Processor

B. Description of Transfer

Categories of data subjects whose Data is transferred: Customer’s authorized users and account administrators of the Asset Management Platform; Customer’s employees whose Data is provided for asset recovery, refresh, deployment, and related IT asset lifecycle management services.

Categories of data transferred:

• Name (First and Last Name)
• Email address (company assigned email)
• Phone number
• Billing address
• Shipping address
• Employee ID and department information
• Cost center and organizational unit assignments
• Device and asset identifiers (serial numbers, IMEI, asset IDs, model numbers)
• Hardware specifications (processor, RAM, storage, condition)
• IP address, browser type, device type, and session data (collected automatically through platform usage)
• Data imported from integrated third-party systems (HRIS, MDM, ticketing, identity provider, and communication platforms) as configured by the Controller
• Data residing on Devices collected for asset recovery, refurbishment, redeployment, or disposition services (“Device-Resident Data”), the contents of which are determined by the Controller and its end users and may include personal data and, incidentally, special categories of personal data (as defined in Article 9 of the EU GDPR). Device-Resident Data is not accessed, read, or used by the Processor and is processed solely for the purpose of secure data sanitization or destruction in accordance with industry-recognized standards

Sensitive data transferred (if applicable) and applied restrictions or safeguards: No sensitive data (as defined under Article 9 of the EU GDPR) is intentionally collected or transferred through the Asset Management Platform. If the Controller inadvertently provides sensitive data through the Platform, the Processor shall notify the Controller promptly. Device-Resident Data may incidentally contain special category data; such data is not accessed or reviewed by the Processor and is subject solely to secure sanitization or destruction, with segregated secure storage of data-bearing devices pending processing.

The frequency of the transfer: Continuous basis during the term of the Agreement.

Nature of the processing: Provision of IT Asset Lifecycle Management services via SaaS platform, including Customer account management, tenant attribution, billing operations, customer support, service delivery communications, asset recovery and deployment logistics, device grading and valuation, and integration with third-party systems as configured by the Controller; and, where the Controller procures asset recovery or disposition services, the physical collection, secure transport, secure storage, and sanitization or destruction of data-bearing devices and any Device-Resident Data thereon, which may be performed by vetted Sub-processors in accordance with Section 11.

Purpose(s) of the data transfer and further processing:

• Attribution of platform tenant to  Customer point of contact
• Customer support and service delivery
• Billing and payment processing
• Service-related communications
• Asset recovery, refresh, deployment, and logistics coordination
• Device inventory management, grading, and valuation
• Reporting and analytics as requested by the Controller

The period for which the Data will be retained: Customer Data is retained for the duration of the Agreement and thereafter only for as long as the Processor has a legitimate business or legal basis to retain it, after which it is returned or deleted in accordance with Section 13 of this DPA. Records that the Processor is required to keep for financial, tax, audit, or legal compliance are retained for the period required under applicable law. Data held in secure backup or disaster-recovery archives is isolated from active processing and deleted in the ordinary course of the Processor’s backup cycle.

For transfers to sub-processors: 

• Subject matter: Provision of infrastructure, payment processing, SMS and email communications, shipping logistics, and product analytics as necessary to deliver the Services.
• Nature: Processing of Data by Sub-processors listed in Annex III solely for the purpose of enabling Unduit to provide the Services.
• Duration: For the term of the Agreement and the period during which Data is returned or deleted in accordance with Section 13.

C. Competent Supervisory Authority

Where the Data exporter is established in an EEA country, the competent supervisory authority is as determined by application of Clause 13 of the EU Standard Contractual Clauses. Where the Data exporter is established in the United Kingdom, the competent supervisory authority is the UK Information Commissioner’s Office (ICO).

ANNEX II

Technical and Organisational Measures

Description of the technical and organisational security measures implemented by the Processor 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 Management System

• Organization. Unduit 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 Data. These policies are updated at least once annually.
• Assessments. Unduit performs risk assessments of systems containing Data at least once annually.
• Risk Treatment. Unduit 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 Data.
• Vendor Management. Unduit maintains an effective vendor management program.
• Incident Management. Unduit reviews security incidents regularly, including effective determination of root cause and corrective action.
• Standards. Unduit operates an information security management system that is covered by a SOC 2 Type II report and certified under the ISO/IEC 27001:2022 standard.

Personnel Security

• Unduit personnel are required to conduct themselves in a manner consistent with the company’s guidelines regarding confidentiality, business ethics, appropriate usage, and professional standards. Unduit conducts reasonably appropriate background checks on any employees who will have access to client data under the Agreement.
• Personnel are required to execute a confidentiality agreement in writing at the time of hire and to protect Data at all times. Personnel must acknowledge receipt of, and compliance with, Unduit’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 Data are required to complete additional requirements appropriate to their role (e.g., certifications). Unduit’s personnel will not process Data without authorization.

Access Controls

• Access Management. Unduit maintains a formal access management process for the request, review, approval and provisioning of all personnel with access to Data to limit access to properly authorized persons having a need for such access. Access reviews are conducted periodically.
• Authentication. Unduit’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.
• Least Privilege. Unduit’s internal data access processes and policies are designed to protect against unauthorized access, use, disclosure, alteration or destruction of Data. Unduit 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.”
• Password Policy. Where passwords are employed for authentication, password policies follow industry standard practices including complexity requirements, expiry, lockout, restrictions on reuse, and re-prompt after periods of inactivity.

Data Center and Network Security

• Infrastructure. Unduit hosts its production environment with a reputable cloud infrastructure provider in data centers located in the United States. 
• Resiliency. Multiple availability zones are enabled, and Unduit conducts backup restoration testing on a regular basis to ensure resiliency.
• Server Hardening. Unduit’s servers are customized for the application environment and have been hardened for security. Unduit employs a code review process to increase security.
• Disaster Recovery. Unduit replicates data over multiple systems and regularly plans and tests its disaster recovery programs.
• Security Logging. Systems have logging enabled to support security audits and monitor and detect actual and attempted attacks or intrusions.
• Vulnerability Management. Regular vulnerability scans are performed on all infrastructure components. Vulnerabilities are remediated on a risk basis, with Critical, High and Medium security patches installed as soon as commercially possible.

Networks and Transmission

• Data Transmission. Transmissions on production environments use Internet standard protocols with HTTPS encryption (TLS).
• External Attack Surface. Virtual firewalls (security groups) are enforced at the network boundary of the production environment.
• Incident Response. Unduit maintains incident management policies and procedures, including detailed security incident escalation procedures.
• Encryption. Unduit makes HTTPS encryption (TLS) available for data in transit. Data at rest is encrypted using AES-256.

Data Storage, Isolation, and Destruction

Unduit stores data in a multi-tenant environment hosted with its cloud infrastructure provider. Data, the Services database, and file system architecture are replicated across multiple availability zones. Unduit logically isolates the data of different customers. A central authentication system is used across all Services to provide uniform security of data. Unduit ensures secure disposal of customer data through a series of data destruction processes.

Compliance Certifications

• SOC 2 Type II report
• ISO/IEC 27001:2022 certified

ANNEX III

List of Sub-Processors

The Sub-processors engaged by the Processor are listed in Unduit’s Trust Center at trust.unduit.com (the “Sub-processor List”), which may be updated from time to time. The Sub-processor List sets out, for each Sub-processor, a description of its processing, its location, the categories of Data it accesses, and the applicable transfer mechanism. Changes or additions to the Sub-processor List are governed by Section 11 of this DPA.

Note Regarding Other Service Providers:

Unduit utilizes additional third-party services for its own business operations that do not process Data provided under the Agreement. These include website analytics tools, marketing and advertising platforms, visitor identification tools, internal development tools, and project management tools. These services process data collected directly by Unduit from visitors to its own website (unduit.com) and are operated under Unduit’s own controllership. They are not Sub-processors under this DPA.