Data Processing Addendum

Last updated: 19, September, 2025

1. How this Data Processing Addendum (“DPA”) Applies

This DPA forms part of the Terms of Use (hereinafter “Terms”) between you (“you” or “your”) and ClawCloud (Singapore) Private Limited ("ClawCloud", "we", "us", or "our") governing your use of the Services (as defined in the Terms).

2. Definitions

All terms capitalised but not defined in this DPA have the meaning set out in the Terms and/or the Privacy Policy. For the purposes of this DPA, the following expressions shall have the following meanings:

1. “Applicable Data Protection Laws” means the PDPA and any other applicable law, rule, statute, regulation, order, standard and other similar instrument or other enactment pertaining to data protection or the processing of Your Content, in each case as amended, consolidated, re-enacted or replaced from time to time;
2. “DPA” means this Data Processing Addendum;
3. "PDPA" means the Personal Data Protection Act 2012 of Singapore;
4. "Permitted Purpose" means the purpose of providing the Services to you.

3. Description of Processing

Insofar as any personal data within Your Content is collected, used, or disclosed by you via or in connection with the Services, you agree that:

1. any processing of such personal data within Your Content by ClawCloud is solely for your purposes and on your behalf as your data intermediary under the PDPA and processor under Applicable Data Protection Laws; and
2. you remain at all times the controller of Your Content that determines the means and purposes of processing of Your Content and are solely responsible for compliance with all Applicable Data Protection Laws and third-party rights in connection with Your Content.

4. Your Obligations

4.1 You acknowledge and agree:

1. to comply with your obligations under all Applicable Data Protection Laws in relation to your: (i) use of the Platform for processing of any personal data comprised within the Your Content; and (ii) appointment of us as your data intermediary under the PDPA and processor under Applicable Data Protection Laws to process the Your Content as contemplated under this DPA; and
2. that this DPA, the Terms, and any other terms separately agreed in writing between you and ClawCloud relating to your use of the Services will together comprise your complete and final documented instructions to us on the processing of Your Content.

4.2 You represent and warrant to us that:

1. there are no Applicable Data Protection Laws that may prevent us from acting on your instructions and/or performing our obligations under this DPA; and
2. you have at all times complied and continue to comply with the Applicable Data Protection Laws.

4.3 Notwithstanding anything to the contrary hereunder, and without prejudice to Clause 4.2, you acknowledge and agree that it is your sole and exclusive responsibility to, and you shall, do all of the following:

1. in respect of any Your Content, procure and ensure that the relevant data subjects:
   1. are informed of the purposes for which their personal data may be collected, used, disclosed and/or processed by us on behalf of you;
   2. provide all consents necessary for such collection, use, disclosure and/or processing of Your Content by us on behalf of you (if such consents are required under Applicable Data Protection Laws);
   3. ensure that the aforementioned consents are not withdrawn; and
   4. upon our request, provide us with written documentation of the foregoing to our satisfaction (“Documentation”).
2. convey any information notices as required by Applicable Data Protection Laws;
3. make any necessary filings or reporting to the appropriate data protection authority(ies);
4. ensure the accuracy, quality, completeness and legality of the Your Content;
5. comply with any request from any data subject to exercise their rights under Applicable Data Protection Laws, including without limitation requests to access, correct, and/or erase any Your Content of such data subjects;
6. promptly notify us and the relevant data subjects if any breach or failure in protection of Your Content is detected; and
7. at the request of ClawCloud, promptly provide such assistance, do such things (including making arrangements for additional form(s) and consent(s) to be completed and signed by data subjects whose personal data are provided by you) or execute such documents, as ClawCloud may reasonably require, in order to facilitate ClawCloud’s compliance with any Applicable Data Protection Laws.

4.4 You acknowledge and agree ClawCloud shall not be required to, and shall be entitled to refuse to collect, use, disclose and/or process any Your Content without any liability to you or any other person:

1. for which there are no Documentation or for which we reasonably believe there are no Documentation; or
2. in a way that does not comply with the terms hereunder or Applicable Data Protection Laws,

provided that we notify you of such refusal in writing stating its reasons. Any such refusal shall be a breach of the DPA or Terms or constitute a basis for you to allege that ClawCloud has repudiated the Terms.

5. ClawCloud’s Obligations

5.1 ClawCloud shall only process Your Content (including with regard to data transfers) in accordance with, and for the purposes documented in this DPA and any further written instructions from you documented and agreed by ClawCloud as constituting further instructions.

5.2 ClawCloud is hereby granted your general authorisation to engage third party subcontractors, including its affiliates to process the Your Content for the Permitted Purpose, and shall impose data protection terms on any subcontractor it appoints to process any Your Content, that require it to protect such Your Content to at least the standard required by applicable Data Protection Law, or the provisions of this DPA, whichever is more protective.

5.3 At your request, delete or return all Your Content in ClawCloud’s possession following the termination of the Terms. This requirement shall not apply to the extent that ClawCloud is required or permitted by applicable law to retain some or all of the Your Content, in which event ClawCloud shall securely isolate and protect Your Content from any further processing except: (i) to the extent required by such law until deletion is possible; or (ii) where such Data ceases to contain personal data.

5.4 For the avoidance of doubt, nothing herein obliges ClawCloud to disclose any information that is subject to any right, privilege or immunity conferred, or obligation (including without limitation in connection with ClawCloud's performance of any contractual obligation) or limitation imposed, by or under any law or rules of professional conduct in relation to the disclosure of such information.

6. Indemnity

Without prejudice to the indemnity obligations already covered in the Terms, you agree to defend, indemnify and hold ClawCloud harmless from and against any and all suits, actions, claims or proceedings arising from an actual or potential breach of this DPA or Applicable Data Protection Laws by you, or any regulatory, private lawsuit or governmental action relating to any processing of Your Content.

7. Miscellaneous

7.1 This DPA shall remain in force for the duration of the Terms. This DPA forms an integral part of the Terms.

7.2 Unless indicated otherwise, if there is any conflict or inconsistency between the provisions of this DPA and the remainder of the Terms, this DPA shall prevail to the extent of such conflict or inconsistency.

7.3 This DPA and any dispute or claim in connection with it shall be governed by and construed in accordance with the governing law of the Terms, for which this DPA forms a part thereof. You hereby submit to the jurisdiction of the dispute resolution venue(s) as set out in the Terms.