DATA PROCESSING ADDENDUM

(Revision July 2025)

This Data Processing Addendum, including its Schedules, (“DPA”) forms part of the Master Services Agreement between Cerbos and Customer for the purchase of Services from Cerbos (the “Agreement”) to reflect the Parties’ agreement with regard to the Processing of Personal Data.

Customer enters into this DPA on behalf of itself and, to the extent required under applicable Data Protection Laws and Regulations, in the name and on behalf of its Authorized Affiliates. For the purposes of this DPA only, and except where indicated otherwise, the term “Customer” shall include Customer and Authorized Affiliates. All capitalized terms not defined herein shall have the meaning set forth in the Agreement.

In the course of providing the Services to Customer pursuant to the Agreement, Cerbos may Process Personal Data on behalf of Customer and the Parties agree to comply with the following provisions with respect to any Personal Data, each acting reasonably and in good faith:

1. DEFINITIONS

“Authorized Affiliate” means any of Customer’s Affiliate(s) which (a) is subject to the data protection laws and regulations of the European Union, the European Economic Area and/or their member states, Switzerland and/or the United Kingdom, and (b) is permitted to use the Services pursuant to the Agreement between Customer and Cerbos, but has not signed its own Order Form with Cerbos and is not a “Customer” as defined under this DPA.

“Controller” means the entity which determines the purposes and means of the Processing of Personal Data.

“Data Protection Laws and Regulations” means all laws and regulations applicable to the Processing of Personal Data under the Agreement, including those of the United Kingdom, the European Union and their member states.

“Data Subject” means the identified or identifiable person to whom Personal Data relates.

“GDPR” means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation), including as implemented or adopted under the laws of the United Kingdom (UK GDPR).

“Personal Data” means any information relating to (i) an identified or identifiable natural person and, (ii) an identified or identifiable legal entity (where such information is protected similarly as Personal Data or personally identifiable information under applicable Data Protection Laws and Regulations), where for each (i) or (ii): 1) such data is Customer Data or 2) such data is provided by or for Customer to Cerbos as a Processor in order to perform the Professional Services pursuant to an Agreement.

“Processing” or “Process” means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

“Processor” means the entity which Processes Personal Data on behalf of the Controller.

“Professional Services Data” means electronic data constituting Confidential Information, including Personal Data, provided by or for Customer to Cerbos as part of Professional Services.

“Security and Privacy Documentation” means the Security and Privacy Documentation applicable to the specific Services purchased by Customer, as updated from time to time, and accessible via Cerbos’s Trust and Compliance webpage at https://cerbos.dev/legal, via login to the applicable Services, or as otherwise made reasonably available by Cerbos.

“Cerbos Group” means Cerbos and its Affiliates engaged in the Processing of Personal Data.

“Sub-processor” means any Processor engaged by Cerbos or a member of the Cerbos Group.

“Supervisory Authority” means an independent public authority which is established by an EU Member State pursuant to the GDPR.

2. PROCESSING OF PERSONAL DATA

2.1. Roles of the Parties. The parties acknowledge and agree that with regard to the Processing of Personal Data, Customer is a Controller or a Processor, Cerbos is a Processor and that Cerbos or members of the Cerbos Group will engage Sub-processors pursuant to the requirements set forth in section 5 “Sub-processors” below.

2.2. Customer’s Processing of Personal Data. Customer shall, in its use of the Services, Process Personal Data in accordance with the requirements of Data Protection Laws and Regulations, including any applicable requirement to provide notice to Data Subjects of the use of Cerbos as Processor (including where the Customer is a Processor, by ensuring that the ultimate Controller does so). For the avoidance of doubt, Customer’s instructions for the Processing of Personal Data shall comply with Data Protection Laws and Regulations. Customer shall have sole responsibility for the accuracy, quality, and legality of Personal Data and the means by which Customer acquired Personal Data. Customer specifically acknowledges and agrees that its use of the Services will not violate the rights of any Data Subject, including those that have opted-out from sales or other disclosures of Personal Data, to the extent applicable under Data Protection Laws and Regulations.

2.3. Cerbos’s Processing of Personal Data. Cerbos shall treat Personal Data as Confidential Information and shall Process Personal Data on behalf of and only in accordance with Customer’s documented instructions for the following purposes: (i) Processing in accordance with the Agreement and applicable Order Form(s); (ii) Processing initiated by Users in their use of the Services; and (iii) Processing to comply with other documented reasonable instructions provided by Customer (e.g., via email) where such instructions are consistent with the terms of the Agreement.

2.4. Details of the Processing. The subject-matter of Processing of Personal Data by Cerbos is the performance of the Services pursuant to the Agreement. The duration of the Processing, the nature and purpose of the Processing, the types of Personal Data and categories of Data Subjects Processed under this DPA are further specified in Schedule 1 - Details of the Processing to this DPA.

2.5. Customer Instructions. Cerbos shall inform Customer immediately (i) if, in its opinion, an instruction from Customer constitutes a breach of the GDPR and/or (ii) if Cerbos is unable to follow Customer’s instructions for the Processing of Personal Data.

2.6. GDPR. Cerbos will Process Personal Data in accordance with the GDPR requirements directly applicable to Cerbos’s provision of its Services.

3. RIGHTS OF DATA SUBJECTS

Cerbos shall, to the extent legally permitted, promptly notify Customer of any complaint, dispute or request it has received from a Data Subject such as a Data Subject’s right of access, right to rectification, restriction of Processing, erasure (“right to be forgotten”), data portability, object to the Processing, or its right not to be subject to an automated individual decision making, each such request being a “Data Subject Request”. If required by Data Protection Laws and Regulations, Customer shall respond to a Data Subject Request in accordance with the Data Protection Laws and Regulations. Cerbos shall not respond to a Data Subject Request itself, except that Customer authorizes Cerbos to redirect the Data Subject Request as necessary to allow Customer to respond directly. Taking into account the nature of the Processing, Cerbos shall assist Customer by appropriate technical and organizational measures, insofar as this is possible, for the fulfillment of Customer’s obligation to respond to a Data Subject Request under Data Protection Laws and Regulations. In addition, to the extent Customer, in its use of the Services, does not have the ability to address a Data Subject Request, Cerbos shall upon Customer’s request provide commercially reasonable efforts to assist Customer in responding to such Data Subject Request, to the extent Cerbos is legally permitted to do so and the response to such Data Subject Request is required under Data Protection Laws and Regulations. To the extent legally permitted, Customer shall be responsible for any reasonable costs arising from Cerbos’s provision of such assistance.

4. CERBOS PERSONNEL

4.1. Confidentiality. Cerbos shall ensure that its personnel engaged in the Processing of Personal Data are informed of the confidential nature of the Personal Data and have executed written confidentiality agreements. Cerbos shall ensure that such confidentiality obligations survive the termination of the personnel engagement.

4.2. Reliability. Cerbos shall take commercially reasonable steps to ensure the reliability of any Cerbos personnel engaged in the Processing of Personal Data.

4.3. Limitation of Access. Cerbos shall ensure that Cerbos’s access to Personal Data is limited to those personnel performing Services in accordance with the Agreement.

5. SUB-PROCESSORS

5.1. Appointment of Sub-processors. Customer acknowledges and agrees that (a) Cerbos's Affiliates may be retained as Sub-processors; and (b) Cerbos and Cerbos’s Affiliates respectively may engage third-party Sub-processors in connection with the provision of the Services. Cerbos or an Cerbos Affiliate has entered into a written agreement with each Sub-processor containing, in substance, data protection obligations no less protective than those in the Agreement with respect to the protection of Customer Data and/or Personal Data to the extent applicable to the nature of the Services provided by such Sub-processor.

5.2. List of Current Sub-processors and Notification of New Sub-processors. The current list of Sub-processors engaged in Processing Personal Data for the performance of each applicable Service, including a description of their processing activities and countries of location, is listed under the Infrastructure and Sub-processor Documentation which can be found on Cerbos’s Trust and Compliance webpage at (“Infrastructure and Sub-processor Documentation”). Customer hereby consents to these Sub-processors, their locations and processing activities as it pertains to their Personal Data. The Infrastructure and Sub-processor Documentation contains a mechanism to subscribe to notifications of new Sub-processors for each applicable Service, and if Customer subscribes, Cerbos shall provide notification of a new Sub-processor(s) before authorizing any new Sub-processor(s) to Process Personal Data in connection with the provision of the applicable Services.

5.3. Objection Right for New Sub-processors. Customer may object to Cerbos’s use of a new Sub-processor by notifying Cerbos promptly in writing within thirty (30) days of receipt of Cerbos’s notice in accordance with the mechanism set out in section 5.2. If Customer objects to a new Sub-processor as permitted in the preceding sentence, Cerbos will use reasonable efforts to make available to Customer a change in the Services or recommend a commercially reasonable change to Customer’s configuration or use of the Services to avoid Processing of Personal Data by the objected-to new Sub-processor without unreasonably burdening Customer. If Cerbos is unable to make available such change within a reasonable period of time, which shall not exceed sixty (60) days, Customer may terminate the applicable Order Form(s) with respect only to those Services which cannot be provided by Cerbos without the use of the objected-to new Sub-processor by providing written notice to Cerbos. Cerbos will refund Customer any prepaid fees covering the remainder of the term of such Order Form(s) following the effective date of termination with respect to such terminated Services, without imposing a penalty for such termination on Customer.

5.4. Liability. Cerbos shall be liable for the acts and omissions of its Sub-processors to the same extent Cerbos would be liable if performing the services of each Sub-processor directly under the terms of this DPA.

6. SECURITY

6.1. Controls for the Protection of Customer Data & Personal Data. Cerbos shall maintain appropriate technical and organizational measures for protection of the security (including protection against unauthorized or unlawful Processing and against accidental or unlawful destruction, loss or alteration or damage, unauthorized disclosure of, or access to, Customer Data and Professional Services Data), confidentiality and integrity of Customer Data and Professional Services Data, as set forth in the Security and Privacy Documentation. Cerbos regularly monitors compliance with these measures. Cerbos will not materially decrease the overall security of the Services during a subscription term.

6.2. Cooperation and Audits. Cerbos shall make available to Customer such information as is reasonably requested by Customer to demonstrate its compliance with applicable statutory obligations, in a commonly used and machine-readable format, to the extent such information is available to Cerbos. In cases of official requests of data protection authorities with jurisdiction over the Processing hereunder, or, in case Customer has reasonable grounds to assume that a Data Incident has taken place, Customer may upon at least fourteen (14) days prior written notice to Cerbos conduct a site visit of the applicable Cerbos operations center at Customer’s expense by a representative of Customer or its independent third party auditor (always not a direct competitor of Cerbos). Such audits shall be carried out at normal business hours without disrupting the ongoing business operations of Cerbos. Cerbos may make the audits dependent on the signing of a nondisclosure agreement with Cerbos.

6.3. Data Protection Impact Assessment. Upon Customer’s request, Cerbos shall provide Customer with reasonable cooperation and assistance needed to fulfill Customer’s obligation under Data Protection Laws and Regulations to carry out a data protection impact assessment related to Customer’s use of the Services, to the extent Customer does not otherwise have access to the relevant information, and to the extent such information is available to Cerbos.

7. DATA INCIDENT NOTIFICATION

7.1. Cerbos responsibilities. Cerbos shall notify Customer without undue delay after becoming aware of the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Customer Data or Professional Services Data, transmitted, stored or otherwise Processed by Cerbos or its Sub-processors of which Cerbos becomes aware (a “Data Incident”). Cerbos shall make reasonable efforts to identify the cause of such Data Incident and take such steps as Cerbos deems necessary and reasonable to remediate the cause of such a Data Incident to the extent the remediation is within Cerbos’s reasonable control. The obligations herein shall not apply to incidents that are caused by Customer or Customer’s Users.

7.2. Customer responsibilities. If required under Data Protection Laws and Regulations, Customer shall notify Data Incident to the relevant authorities or Data Subjects in accordance with the Data Protection Laws and Regulations.

8. RETURN AND DELETION OF CUSTOMER DATA

The procedure is set forth in Section 2.2 of the Agreement.

9. DATA TRANSFERS

Cerbos shall ensure that the transfer of Personal Data which are undergoing Processing or are intended for Processing after transfer to a third country shall take place only if such transfer meets the conditions outlined in the GDPR, specifically Chapter V.

10. AUTHORIZED AFFILIATES

10.1. Contractual Relationship. The parties acknowledge and agree that, by executing the Agreement, Customer enters into this DPA on behalf of itself and, as applicable, in the name and on behalf of its Authorized Affiliates, thereby establishing a separate DPA between Cerbos and each such Authorized Affiliate subject to the provisions of the Agreement and this section 10 and section 11. Each Authorized Affiliate agrees to be bound by the obligations under this DPA and, to the extent applicable, the Agreement. For the avoidance of doubt, an Authorized Affiliate is not and does not become a party to the Agreement, and is a party only to this DPA. All access to and use of the Services by Authorized Affiliates must comply with the terms and conditions of the Agreement and any violation of the terms and conditions of the Agreement by an Authorized Affiliate shall be deemed a violation by Customer.

10.2. Communication. The Customer that is the contracting party to the Agreement shall remain responsible for coordinating all communication with Cerbos under this DPA and be entitled to make and receive any communication in relation to this DPA on behalf of its Authorized Affiliates.

10.3. Rights of Authorized Affiliates. Where an Authorized Affiliate becomes a party to this DPA with Cerbos, it shall to the extent required under applicable Data Protection Laws and Regulations be entitled to exercise the rights and seek remedies under this DPA, subject to the following:

10.3.1 Except where applicable Data Protection Laws and Regulations require the Authorized Affiliate to exercise a right or seek any remedy under this DPA against Cerbos directly by itself, the parties agree that (i) solely the Customer that is the contracting party to the Agreement shall exercise any such right or seek any such remedy on behalf of the Authorized Affiliate, and (ii) the Customer that is the contracting party to the Agreement shall exercise any such rights under this DPA, not separately for each Authorized Affiliate individually, but in a combined manner for itself and all of its Authorized Affiliates together (as set forth, for example, in section 10.3.2, below).

10.3.2 The parties agree that the Customer that is the contracting party to the Agreement shall, when carrying out an on-site audit of the procedures relevant to the protection of Personal Data, take all reasonable measures to limit any impact on Cerbos and its Sub-Processors by combining, to the extent reasonably possible, several audit requests carried out on behalf of itself and all of its Authorized Affiliates in one single audit.

11. LIMITATION OF LIABILITY

Each party’s and all of its Affiliates’ liability, taken together in the aggregate, arising out of or related to this DPA, and all DPAs between Authorized Affiliates and Cerbos, whether in contract, tort or under any other theory of liability, is subject to the ‘Limitation of Liability’ section of the Agreement, and any reference in such section to the liability of a party means the aggregate liability of that party and all of its Affiliates under the Agreement and all DPAs together.

For the avoidance of doubt, Cerbos’s and its Affiliates’ total liability for all claims from Customer and all of its Authorized Affiliates arising out of or related to the Agreement and all DPAs shall apply in the aggregate for all claims under both the Agreement and all DPAs established under the Agreement, including by Customer and all Authorized Affiliates, and, in particular, shall not be understood to apply individually and severally to Customer and/or to any Authorized Affiliate that is a contractual party to any such DPA.

List of Schedules

Schedule 1: - Details of the Processing

SCHEDULE 1 - DETAILS OF THE PROCESSING

Nature and Purpose of Processing

Cerbos will Process Personal Data as necessary to perform the Services pursuant to the Agreement, as further specified in the Documentation, and as further instructed by Customer in its use of the Services.

Duration of Processing

Subject to Section 8 of the DPA, Cerbos will Process Personal Data for the duration of the Agreement, unless otherwise agreed upon in writing.

Categories of Data Subjects

Customer may submit Personal Data to the Services, the extent of which is determined and controlled by Customer in its sole discretion, and which may include, but is not limited to Personal Data relating to the following categories of data subjects:

● Customer’s staff

● Customer’s Users authorized by Customer to use the Services

● Customer’s users of its applications

Type of Personal Data

Customer may submit Personal Data to the Services, the extent of which is determined and controlled by Customer in its sole discretion, and which may include, but is not limited to the following categories of Personal Data:

● For all categories of data subjects - First and last name, ID data, Contact information (email, phone, physical address), position and employer.

● Usage data – IP Address

● Access request logs data, application logs data of the policy decision point(s)

● Access policies for security