Idera Affiliates Data Processing Terms
(for the Customer-Facing DPA)

Details of Processing of Qubole, Inc.

1. Address:
   4001 W. Parmer Lane, Suite 125 , Austin, TX 78727

2. Type of Services provided by the Idera Affiliate involving the Processing of Customer Personal Data:

   Qubole is a simple, open, and secure Data Lake Platform for machine learning, streaming, and ad-hoc analytics. Our platform provides end-to-end services that reduce the time and effort required to run Data pipelines, streaming analytics, and machine learning workloads on any cloud.

3. Data Protection Officer (DPO) Details:

   VeraSafe, LLC, a Delaware limited liability company. [email protected]

4. EU Data Protection Representative:

   VeraSafe Ireland Ltd.

   Unit 3D North Point House North Point Business Park New Mallow Road, Cork T23AT2P Ireland Contact form: https://verasafe.com/public-resources/contact-data-protection-representative https://verasafe.com/public-resources/contact-data-protection-representative

5. UK Data Protection Representative:

   n/a

6. Subject matter and duration:

   The subject matter and duration of the Processing of Customer Personal Data are set forth in the Main Agreement and all amendments, exhibits, schedules, task orders, addenda, SOWs, purchase orders and other documents associated therewith and incorporated therein.

7. Nature and Purpose of Processing:

   The nature and purpose of the Processing of Customer Personal Data are set forth in the Main Agreement and all amendments, exhibits, schedules, task orders, addenda, SOWs, purchase orders and other documents associated therewith and incorporated therein.

8. Further Processing:

   No further Processing of Customer Personal Data beyond the Processing necessary for the provision of the Services is allowed.

9. Categories of Data Subjects:

   Data subjects may include Customer’s representatives, such as employees, contractors, collaborators, partners. Data subject may also include individuals attempting to communicate or transfer Customer Personal Data to users of the Services.

10. Categories of Customer Personal Data:

    The Categories of Customer Personal Data that Customer authorizes and requests that Qubole Processes include but are not limited to: Personal contact information such as full name, address, mobile number, email address; details including employer name, job title and function, identification numbers and business contact details; goods or services provided; IP addresses and interest data.

11. Special Categories of Customer Personal Data to be Processed (if applicable) and the applied restrictions to the Processing of these Special Categories of Customer Personal Data:

    n/a

12. Categories of third-party recipients to whom the Customer Personal Data may be disclosed or shared by Idera:

    Subprocessors; and Other Idera Affiliates, if applicable.

13. Frequency of the Transfer of Customer Personal Data:

    The frequency of the transfer of Customer Personal Data is determined by the Customer. Customer Personal Data is transferred each time that the Customer instructs Qubole to Process Customer Personal Data.

14. Maximum data retention periods, if applicable:

    The retention period of the Customer Personal Data is generally determined by the Customer and is subject to the term of the DPA and the Main Agreement, respectively, in the context of the contractual relationship between Qubole and the Customer.

15. The basic Processing activities to which Customer Personal Data will be subject include, without limitation:

    Collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction for the purpose of providing the Services to Customer in accordance with the terms of the Main Agreement.

16. The following is deemed an instruction by the Customer to Qubole to Process Customer Personal Data:

    1. Processing in accordance with the Main
    2. Processing initiated by Data Subjects in their use of the Services
    3. Processing to comply with other reasonable documented instructions provided by Customer (e.g., via email) where such instructions are consistent with the terms of the Main Agreement

17. List of Qubole's Subprocessors are available at

    https://www.ideracorp.com/Legal/Qubole/Subprocessors.

18. Description of technical and organizational security measures implemented by the Qubole:

    1. Measures of pseudonymization and encryption of Customer Personal Data:

       1. Encryption of the transferred Customer Personal Data in transit using the Transport Layer Security (TLS) protocol version 1.1 or higher with a minimum of 128-bit encryption;
       2. Encryption at rest within Qubole's software applications using a minimum of AES-256

    2. Measures for ensuring ongoing confidentiality, integrity, availability and resilience of Processing systems and services:

       1. Restriction of logical access to IT systems that Process transferred Customer Personal Data to those officially authorized persons with an identified need for such access;
       2. Active monitoring of production host session for potential security events, including intrusion;
       3. Regular scanning and monitoring of any unauthorized software applications and IT systems for vulnerabilities of Qubole; and
       4. Firewall protection of external points of connectivity in Data Importers network architecture

    3. Measures for ensuring the ability to restore the availability and access to Customer Personal Data in a timely manner in the event of a physical or technical incident:

       1. All servers are built via automation and scale elastically. In the event of a node failure, a new one is spun up to take its place. Data is stored in AWS S3 (and other S3-backed technologies such as EBS/RDS) which is automatically backed up and kept highly available.

    4. Processes for regularly testing, assessing, and evaluating the effectiveness of technical and organizational measures in order to ensure the security of the Processing:

       1. Compliance program to track security controls; and
       2. Vulnerabilities are addressed as they are discovered.

    5. Measures for user identification and authorization:

       1. Users are provided passwords to enter the application and these passwords are stored hashed inside the database; and
       2. There is a custom application permission system to guarantee that users have access only to data that is appropriate to their access level

    6. Measures for the protection of data during transmission:

       1. Encryption of the transferred Customer Personal Data in transit using the Transport Layer Security (TLS) protocol version 1.1 or higher with a minimum of 128-bit encryption.

    7. Measures for the protection of data during storage:

       1. Data is stored using a leading service that ensures high performance, scalability, availability and security by default; and
       2. Access is role based and reviewed regularly.

    8. Measures for ensuring physical security of locations at which Customer Personal Data are processed:

       1. Restriction of physical to IT systems that Process transferred Customer Personal Data to those officially authorized persons with an identified need for such access.

    9. Measures for ensuring events logging:

       1. Active monitoring and logging of network and database activity for potential security events, including intrusion.

    10. Measures for ensuring system configuration, including default configuration:

        1. System configuration is driven largely off of automation

    11. Measures for internal IT and IT security governance and management:

        1. Users are created with only required permissions and access roles; and
        2. Permissions are reviewed and removed regularly.

    12. Measures for certification/assurance of processes and products:

        1. Qubole is Type 2 SOC 2 certified

    13. Measures for ensuring data minimization:

        1. Data minimization is guaranteed during the design and implementation processes.

    14. Measures for ensuring data quality:

        1. Customer is responsible for data quality and accuracy since the data is provided by the Customer; and
        2. Form validations are made to validate some fields.

    15. Measures for ensuring limited data retention:

        1. Different policies can apply depending on the type of data.

    16. Measures for ensuring accountability:

        1. Documentation about how personal data is processed.

    17. Measures for allowing data portability and ensuring erasure:

        1. In-product feature to allow data portability that securely transmits the data structured in a readable format.
        2. A formal Compliance process for deleting Customer Personal Data by making a support request to [email protected]

    18. Other:

        1. Internal policies establishing that
           
           1. Where Qubole is prohibited by law from notifying Data Exporter of an order from a public authority for transferred Customer Personal Data, Qubole shall take into account the laws of other jurisdictions and use best efforts to request that any confidentiality requirements be waived to enable it to notify the competent Supervisory Authorities;
           2. Qubole must require an official, signed document issued pursuant to the applicable laws of the requesting third party before it will consider a request for access to transferred Customer Personal Data;
           3. Qubole shall scrutinize every request for legal validity and, as part of that procedure, will reject any request Data Importer considers to be invalid; and
           4. If Qubole is legally required to comply with an order, it will respond as narrowly as possible to the specific