Semaloop

Platform Data Processing Agreement

Last updated: 1 March 2026

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PARTIES AND EXECUTION

Entity details:

Semaloop Ltd

Company number: 16675807

Registered office address: 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ

(referred to as “Semaloop” in the Main Agreement and “Semaloop” or “Processor” in this DPA).

Entity details:

The “Customer” as set out in the Main Agreement.

(referred to as “Customer” in the Main Agreement and “Customer” or “Controller” in this DPA).

Signature:

Signed in accordance with the Main Agreement.

Signature:

Signed in accordance with the Main Agreement.

Name:

Name:

Title:

Title:

Date:

Date:

VARIABLES

Parties’ relationship

Controller to Processor

Parties’ roles

Customer will act as the Controller (as defined in Section 1 of the Terms)

Semaloop will act as the Processor (as defined in Section 1 of the Terms)

Contacts

Controller

Processor

Name:

Email:

As set out in the Notices clause (Clause 12.12(a)(ii)) of the Main Agreement.

Name:

Email:

As set out in the Notices clause (Clause 12.2(a)(i)) of the Main Agreement.

Main Agreement

The Agreement entered into between Semaloop and the Customer in relation to the provision of the Platform under and in accordance with the “Semaloop Platform Terms of Service” at semaloop.com/terms

Term

This DPA will commence on the Effective Date as set out in the Main Agreement and will continue for the Term as set out in the Main Agreement.

Breach Notification Period

Without undue delay after becoming aware of a personal data breach

Sub-processor Notification Period

A reasonable timeframe before the new sub-processor is granted access to Personal Data

Liability Cap

Each party’s aggregate liability under this DPA will not exceed the liability caps as per the Main Agreement

Governing Law and Jurisdiction

As per the Main Agreement

Data Protection Laws

All laws, regulations and court orders which apply to the processing of Personal Data in the United Kingdom (UK). This includes the UK GDPR and the Data Protection Act 2018, each as amended from time to time.

Services related to processing

As described in the Main Agreement (the “Platform”)

Duration of processing

For the Term of this DPA

Nature and purpose of processing

Known Personal Data. The purpose of the Personal Data processing for the identifiable in-scope personal data is to enable the Customer’s personnel to access and use the Dashboard and for Semaloop to provide the Platform. This includes the collection, storage, updating and deletion of such Personal Data.

Unknown Personal Data. Any unknown Personal Data is such data that the Processor is not able to easily identify as subject to processing (as of the Effective Date) but may be processed in order to provide the Platform. To the extent that such unknown Personal Data is processed by Semaloop, the purpose is purely to enable Semaloop to deliver the Platform and, if the parties have agreed that Semaloop may use Customer Data to do so in the Main Agreement, to improve its product and train its AI models (here, acting as a controller in its own right).

Personal Data

Known Personal Data

The types of personal data processed are:

Customer’s personnel

  • Identity Data: first name, last name, profile picture
  • Contact Data: email address (work)

Unknown Personal Data

Customer’s customers or Customer’s customer’s customers

Semaloop may also process the Customer’s customer’s personal data that is not identifiable as of the Effective Date, in order to provide the Platform. Specifically, this may include any Customer’s customer’s personal data that is presented in the Customer’s mobile app for a Test. For example, names and pictures of other app users or comments and posts made by such users. This may include special categories of personal data.

Data subjects

The individuals whose Personal Data will be processed are:

  • Customer’s personnel

And may include:

  • Customer’s customers (consumers or business users)
  • Customer’s customer’s customers (consumers or business users)

and any other data subjects whose Personal Data may be processed by the Processor in order to provide the Platform.

Special provisions

None

Transfer Mechanism

N/A

ANNEX 1

Security measures. Technical and organisational measures to ensure the security of Personal Data

Technical measures

  • Encryption of customer data in transit (TLS) and at rest (AES-256 or equivalent).
  • Role-based access control and least privilege to restrict system and data access.
  • Multi-factor authentication for administrative and production system access.
  • Logging and monitoring of infrastructure and application activity, including authentication events and administrative actions.
  • Network security protections, including firewalls, restricted inbound access, and secure cloud configuration.
  • Secure software development practices, including code review, version control, and security testing before deployment.
  • Vulnerability management, including periodic vulnerability scanning and remediation based on severity.
  • Segregation of development and production environments to prevent unauthorised access to production data.
  • Regular backups and recovery procedures designed to support system restoration and availability.

Organisational measures

  • Documented information security policies and procedures governing the protection of customer data.
  • Defined security roles and responsibilities with oversight of security and compliance programs.
  • Employee security awareness training at onboarding and periodically thereafter.
  • Confidentiality obligations for employees and contractors with access to company systems or customer data.
  • Access management procedures, including approval, periodic access reviews, and timely revocation upon role change or termination.
  • Incident response processes for detecting, responding to, and resolving security incidents.
  • Business continuity and disaster recovery planning, including periodic testing of recovery capabilities.
  • Vendor and sub-processor risk management, including security due diligence and contractual security requirements.
  • Independent security audits and monitoring, including SOC 2 Type 2 assessments.

ANNEX 2

Sub-processors. Current sub-processors

Name of Sub-processor

Location of Processing

Transfer mechanism

Cloudflare

Worldwide

EU-U.S. Data Privacy Framework / UK Extension; EU SCCs + UK Addendum

Google Cloud

Worldwide

EU-U.S. Data Privacy Framework / UK Extension; EU SCCs incorporated in the CDPA

Anthropic (Claude)

United States

EU SCCs + UK Addendum

OpenAI

United States

EU SCCs + UK Addendum

Modal

United States

EU SCCs + UK IDTA

Cerebras

United States

EU SCCs + UK Addendum

Moondream

United States

EU SCCs + UK Addendum

ElevenLabs

United States

EU-U.S. Data Privacy Framework / UK Extension; EU SCCs + UK Addendum

WorkOS

United States

EU SCCs + UK Addendum

PostHog

Germany

N/A

Pydantic Logfire

Netherlands

N/A

TERMS

  1. What is this agreement about?
    1. Purpose. The parties are entering into this Data Processing Agreement (DPA) for the purpose of processing Personal Data (as defined above).
    2. Definitions. Under this DPA:
      1. adequate country means a country or territory that is recognised under Data Protection Laws from time to time as providing adequate protection for processing Personal Data, and
      2. Controller, data subject, personal data breach, process/processing, Processor and supervisory authority have the same meanings as in the Data Protection Laws.
  1. What are each party’s obligations?
    1. Controller obligations. Controller instructs Processor to process Personal Data in accordance with this DPA, and is responsible for providing all notices and obtaining all consents, licences and legal bases required to allow Processor to process Personal Data.
    2. Processor obligations. Processor will:
      1. only process Personal Data in accordance with this DPA and Controller’s instructions (unless legally required to do otherwise),
      2. not sell, retain or use any Personal Data for any purpose other than as permitted by this DPA and the Main Agreement,
      3. inform Controller immediately if (in its opinion) any instructions infringe Data Protection Laws,
      4. use the technical and organisational measures described in Annex 1 when processing Personal Data to ensure a level of security appropriate to the risk involved,
      5. notify Controller of a personal data breach within the Breach Notification Period and provide assistance to Controller as required under Data Protection Laws in responding to it,
      6. ensure that anyone authorised to process Personal Data is committed to confidentiality obligations,
      7. without undue delay, provide Controller with reasonable assistance with:
        1. data protection impact assessments,
        2. responses to data subjects’ requests to exercise their rights under Data Protection Laws, and
        3. engagement with supervisory authorities,
      8. if requested, provide Controller with information necessary to demonstrate its compliance with obligations under Data Protection Laws and this DPA,
      9. allow for audits at Controller’s reasonable request, provided that audits are limited to once a year and during business hours except in the event of a personal data breach, and
      10. return Personal Data upon Controller’s written request or delete Personal Data by the end of the Term, unless retention is legally required.
    3. Warranties. The parties warrant that they and any staff and/or subcontractors will comply with their respective obligations under Data Protection Laws for the Term.
  1. Sub-processing
    1. Use of sub-processors. Controller authorises Processor engage other processors (referred to in this section as sub-processors) when processing Personal Data. Processor’s existing sub-processors are listed in Annex 2.
    2. Sub-processor requirements. Processor will:
      1. require its sub-processors to comply with equivalent terms as Processor’s obligations in this DPA,
      2. ensure appropriate safeguards are in place before internationally transferring Personal Data to its sub-processor, and
      3. be liable for any acts, errors or omissions of its sub-processors as if they were a party to this DPA.
    3. Approvals. Processor may appoint new sub-processors provided that they notify Controller in writing in accordance with the Sub-processor Notification Period.
    4. Objections. Controller may reasonably object in writing to any future sub-processor. If the parties cannot agree on a solution within a reasonable time, either party may terminate this DPA.
  1. International personal data transfers
    1. Instructions. Processor will transfer Personal Data outside the UK, the EEA or an adequate country only on documented instructions from Controller, unless otherwise required by law.
    2. Transfer mechanism. Where a party is located outside the UK, the EEA or an adequate country and receives Personal Data:
      1. that party will act as the data importer,
      2. the other party is the data exporter, and
      3. the relevant Transfer Mechanism will apply.
    3. Additional measures. If the Transfer Mechanism is insufficient to safeguard the transferred Personal Data, the data importer will promptly implement supplementary measures to ensure Personal Data is protected to the same standard as required under Data Protection Laws.
    4. Disclosures. Subject to terms of the relevant Transfer Mechanism, if the data importer receives a request from a public authority to access Personal Data, it will (if legally allowed):
      1. challenge the request and promptly notify the data exporter about it, and
      2. only disclose to the public authority the minimum amount of Personal Data required and keep a record of the disclosure.
  1. Other important information
    1. Survival. Any provision of this DPA which is intended to survive the Term will remain in full force.
    2. Order of precedence. In case of a conflict between this DPA and other relevant agreements, they will take priority in this order:
      1. Transfer Mechanism,
      2. DPA,
      3. Main Agreement.
    3. Notices. Formal notices under this DPA must be in writing and sent to the Contact on the DPA’s front page as may be updated by a party to the other in writing.
    4. Third parties. Except for affiliates, no one other than a party to this DPA has the right to enforce any of its terms.
    5. Entire agreement. This DPA supersedes all prior discussions and agreements and constitutes the entire agreement between the parties with respect to its subject matter and neither party has relied on any statement or representation of any person in entering into this DPA.
    6. Amendments. Any amendments to this DPA must be agreed in writing.
    7. Assignment. Neither party can assign this DPA to anyone else without the other party's consent.
    8. Waiver. If a party fails to enforce a right under this DPA, that is not a waiver of that right at any time.
    9. Governing law and jurisdiction. The Governing Law applies to this DPA and all disputes will only be litigated in the courts of the Jurisdiction.
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