DATA PROCESSING ADDENDUM

Enterprise data protection for Hayrok customers.

Hayrok processes security and operational data on behalf of customers using the Hayrok platform. The DPA establishes the privacy, security, confidentiality, subprocessor, international-transfer, data-subject-rights, incident-response, deletion, and audit obligations that apply.

GDPRSUBPROCESSORSTRANSFERSINCIDENT RESPONSE
VERSION
HYR-DPA v1.4
EFFECTIVE
2026-04-01
GOVERNS
Processor obligations under customer agreements
SUPPORTS
GDPR · UK GDPR · CCPA / CPRA · U.S. state laws
01 · DPA OVERVIEW

Clear responsibilities for customer data.

When Hayrok processes personal data on your behalf.

When a customer determines why and how personal data is processed through Hayrok, and Hayrok processes that information to provide the contracted service, the customer generally acts as the Controller and Hayrok acts as the Processor — using GDPR terminology. The DPA establishes how Hayrok handles that Customer Personal Data on the customer's behalf.

THE DPA ADDRESSES
  • Processing instructions
  • Confidentiality
  • Security safeguards
  • Subprocessors
  • Data-subject requests
  • Security incidents
  • International transfers
  • Data deletion & return
  • Audit & compliance support
  • Customer responsibilities
  • AI & third-party processing
  • Private Runner considerations
02 · WHEN THE DPA APPLIES

Processing Customer Personal Data through Hayrok.

The DPA applies where Hayrok processes personal data on behalf of a customer in connection with the applicable Hayrok agreement. Customer Personal Data may appear across these information classes:

CLASS · 01

User & Identity Data

  • User identifiers
  • Email addresses
  • Organization membership
  • Identity-provider metadata
  • Roles & permissions
  • Service-account information
CLASS · 02

Asset Data

  • Applications & APIs
  • Cloud resources
  • Workloads
  • Repositories
  • Infrastructure metadata
CLASS · 03

Security Telemetry

  • Identity events
  • WAF records
  • API gateway events
  • Cloud & Kubernetes logs
  • Application & detection events
CLASS · 04

Security Findings

  • Vulnerability information
  • Misconfigurations
  • Validation outcomes
  • Remediation information
CLASS · 05

Validation Evidence

  • Request & response metadata
  • Runtime observations
  • Detection events
  • Control responses · reachability
  • Screenshots · approval history
  • Execution metadata
CLASS · 06

AI Context (where enabled)

  • Nectar prompts
  • Evidence references
  • Finding & attack-path context
  • Generated responses
  • AI interaction metadata
i
The precise data processed depends on customer configuration, integrations, scope, and enabled Hayrok capabilities. Nothing above is universally in-scope for every deployment.
03 · CUSTOMER & HAYROK ROLES

Who does what.

CONTROLLER

Customer responsibilities

  • Lawful collection of Customer Personal Data
  • Providing appropriate notices
  • Establishing a lawful basis where required
  • Defining authorized users
  • Configuring integrations
  • Determining validation scope
  • Issuing processing instructions
  • Responding to individuals where the customer is Controller
PROCESSOR

Hayrok responsibilities

Hayrok processes Customer Personal Data according to:

  • The customer agreement
  • The DPA
  • Customer configuration
  • Documented customer instructions
  • Applicable legal obligations
!
Hayrok notifies the customer where it reasonably believes an instruction violates applicable data-protection law, subject to counsel-approved contractual language.
04 · DOCUMENTED PROCESSING INSTRUCTIONS

Customer-controlled processing.

Hayrok processes Customer Personal Data only for purposes necessary to provide, maintain, and secure the Hayrok service; provide customer support; perform authorized validation; generate evidence and reports; operate authorized integrations; provide enabled AI capabilities; and meet applicable legal obligations.

CONFIGURATION IS INSTRUCTION
  • Selecting integrations
  • Configuring validation objectives
  • Defining assets & scope
  • Establishing user permissions
  • Setting retention options
  • Enabling / disabling functionality
Never
Hayrok does not independently repurpose Customer Personal Data for unrelated commercial purposes contrary to the DPA.
05 · DETAILS OF PROCESSING

The annex, in shorthand.

SUBJECT MATTER

Provision of Hayrok's Governed Adversarial Exposure Validation platform and associated services.

DURATION

For the term of the customer agreement, plus any limited period necessary for authorized retention, deletion, backup lifecycle, security, or legal requirements.

NATURE OF PROCESSING
  • Collection
  • Transmission
  • Storage
  • Organization & retrieval
  • Analysis & correlation
  • Validation
  • AI-assisted reasoning
  • Evidence generation
  • Reporting
  • Deletion
PURPOSE

To deliver and secure the Hayrok services selected by the customer.

06 · CATEGORIES OF DATA SUBJECTS

Whose personal data may appear.

  • Customer employees
  • Customer contractors
  • Authorized Hayrok users
  • Developers & administrators
  • Security personnel
  • Application users
  • Customer end users
  • Individuals in security logs / telemetry
  • Business contacts
  • Others in customer-controlled systems
Data minimization is shared. Customers should avoid submitting unnecessary personal data to Hayrok.
07 · CATEGORIES OF PERSONAL DATA

What may be processed.

IDENTIFICATION
  • Name · email
  • User & account identifiers
PROFESSIONAL
  • Employer · department
  • Role · job function
IDENTITY & ACCESS
  • Roles & permissions
  • Account metadata
  • Authentication-event metadata
  • Service-account identifiers
TECHNICAL
  • IP addresses · device IDs
  • Application & API metadata
  • Log information
SECURITY
  • Security events
  • Findings
  • Detection records
  • Validation evidence
  • Attack-path relationships
  • Remediation activity
By design
Hayrok does not intentionally require customers to submit special-category or highly sensitive personal data unless necessary for an explicitly authorized service workflow.
08 · SECURITY MEASURES

Protecting Customer Personal Data.

Hayrok maintains technical and organizational measures designed to protect Customer Personal Data against unauthorized access, use, alteration, loss, or disclosure. The DPA incorporates or references Hayrok's current security measures.

IDENTITY & ACCESS
  • Strong authentication
  • Enterprise identity integration
  • Role-based authorization
  • Contextual policy evaluation
  • Least privilege
  • Administrative access controls
TENANT ISOLATION
  • Tenant-aware authorization
  • Tenant-scoped data access
  • Tenant-aware evidence handling
  • Tenant-specific integrations
  • Cross-tenant access controls
NETWORK SECURITY
  • Edge protection
  • Gateway enforcement
  • Network restrictions
  • Service-to-service auth
  • Mutual TLS where implemented
ENCRYPTION
  • Encryption in transit
  • Encryption at rest
  • Secrets protection
  • Key-management controls
APPLICATION SECURITY
  • Secure development
  • Code review
  • Dependency security
  • Container security
  • Security testing · vuln mgmt
MONITORING
  • Authentication monitoring
  • Authorization logging
  • Security telemetry
  • Infrastructure monitoring
  • Audit logging · investigation
RESILIENCE
  • Backup controls
  • Recovery procedures
  • Operational monitoring
  • Incident-response processes
09 · GOVERNED ADVERSARIAL VALIDATION

Security testing does not remove privacy obligations.

Hayrok may perform adversarial validation against systems explicitly authorized by the customer. Validation remains subject to:

  • Customer authorization
  • Defined scope
  • Policy controls
  • Safety requirements
  • Tool restrictions
  • Approval gates where required
  • Evidence requirements
  • Auditability
Customers remain responsible for ensuring they are authorized to submit the relevant assets, systems, identities, and data. Hayrok does not treat security-testing capabilities as blanket permission to process unrelated information.
10 · NECTAR & AI PROCESSING

AI processing remains within the customer data relationship.

Nectar is Hayrok's evidence-grounded intelligence and reasoning layer. Where Nectar processes Customer Personal Data on your behalf, that processing remains subject to the DPA.

NECTAR MAY
  • Explain findings
  • Interpret evidence
  • Analyze attack paths
  • Summarize defensive response
  • Recommend remediation
  • Summarize reports
  • Guide revalidation
AUTHORIZATION

AI retrieval is constrained by the requesting user's tenant, organization, permissions, and resource access.

THIRD-PARTY PROVIDERS

Where Hayrok engages a third-party AI provider to process Customer Personal Data on Hayrok's behalf, the provider is treated as a subprocessor.

Training commitment. Hayrok will not use Customer Personal Data to train general-purpose AI models or permit a subprocessor to do so except as expressly authorized by Customer — subject to final contractual language approved by counsel and Hayrok's verified provider configuration.
11 · CONFIDENTIALITY

Access limited to authorized personnel.

Hayrok personnel with access to Customer Personal Data are subject to appropriate confidentiality obligations. Access is limited according to job responsibilities, least privilege, customer-support requirements, security responsibilities, and approved administrative workflows.

Customer Personal Data does not become accessible to Hayrok personnel merely because the information exists in the platform. Privileged administrative access is controlled and auditable.
12 · SUBPROCESSORS

Providers supporting the Hayrok service.

Hayrok may engage subprocessors to provide infrastructure or functionality required to operate the service. Hayrok contractually requires subprocessors that process Customer Personal Data to provide data-protection obligations appropriate to the services they perform, consistent with GDPR Article 28.

CATEGORIES
  • Cloud infrastructure
  • Authentication
  • Communications
  • Observability
  • AI services
  • Customer support
  • Business operations
The Trust Center maintains an up-to-date list — provider · purpose · service · data categories · processing location.
13 · SUBPROCESSOR CHANGES

Enterprise transparency.

The DPA defines Hayrok's process for adding or replacing subprocessors — publication of the current list, advance notice of material changes, customer subscription to change notifications, and a defined objection mechanism where legally or contractually required.

Practical objection model. Customer may raise a reasonable data-protection objection within the period specified in the DPA, and the parties will work in good faith toward an appropriate resolution — not an absolute customer veto over every infrastructure provider.
14 · INTERNATIONAL DATA TRANSFERS

Safeguards for cross-border processing.

Where Customer Personal Data is transferred internationally and an applicable law requires a transfer mechanism, Hayrok uses the legally appropriate mechanism for that relationship.

EEA

EU SCCs

European Commission's 2021 Standard Contractual Clauses for transfers to countries outside the EU/EEA.

UNITED KINGDOM

IDTA / UK Addendum

UK International Data Transfer Agreement or the ICO's UK Addendum to the EU SCCs where appropriate.

OTHER JURISDICTIONS

Local mechanisms

Applicable transfer mechanisms required by local law.

No universal adequacy assumption
Do not hard-code an adequacy assumption for every Hayrok customer — the applicable mechanism depends on the specific transfer relationship.
15 · EU STANDARD CONTRACTUAL CLAUSES

SCC incorporation.

Where required, the DPA incorporates the applicable modules of the EU SCCs based on the roles of the parties.

COMMON

Customer Controller → Hayrok Processor

The controller-to-processor structure ordinarily evaluated for direct Hayrok customer relationships.

ALSO SUPPORTED

Customer Processor → Hayrok Subprocessor

The DPA supports the appropriate role configuration rather than assuming every customer has the same legal status.

16 · TRANSFER IMPACT ASSESSMENT SUPPORT

Supporting your transfer reviews.

Where legally required, Hayrok provides information reasonably necessary to help customers evaluate international transfers.

  • Processing locations
  • Subprocessors
  • Security controls
  • Encryption
  • Access-control measures
  • Government-request policies
  • Contractual safeguards
17 · U.S. PRIVACY LAWS

Service provider & contractor processing.

Where applicable U.S. privacy law treats Hayrok as a service provider, contractor, processor, or comparable role, the DPA includes the contractual restrictions needed for that role — for example, California's framework imposes distinct requirements on businesses and on service providers or contractors processing personal information for businesses.

The DPA is drafted broadly enough to support applicable U.S. state processor obligations without forcing customers to sign a separate addendum for every state whenever reasonably possible.
18 · DATA SUBJECT REQUESTS

Helping customers respond to privacy rights.

Where Hayrok acts as Processor, customers remain responsible for responding to requests from individuals concerning Customer Personal Data. Hayrok provides reasonable assistance where required.

REQUESTS MAY INVOLVE
  • Access
  • Correction
  • Deletion
  • Portability
  • Restriction
  • Objection
  • Other applicable rights
Hayrok will not
independently delete Customer Personal Data controlled by a customer simply because an individual contacted Hayrok directly. Direct requests are referred to the relevant customer unless law requires otherwise.
19 · DATA PROTECTION IMPACT ASSESSMENTS

Supporting customer compliance.

Where the customer's use of Hayrok requires a DPIA or regulatory consultation under applicable law, Hayrok provides reasonable information concerning its processing activities and security controls.

  • Processing description
  • Architecture information
  • Subprocessor details
  • Security safeguards
  • Data flows
  • Retention practices
  • AI-processing information

Customer-specific legal conclusions remain the customer's responsibility.

20 · PERSONAL DATA BREACHES

Notification and cooperation.

If Hayrok confirms a Personal Data Breach affecting Customer Personal Data, Hayrok notifies the affected customer without undue delay in accordance with applicable contractual and legal obligations.

NOTIFICATION PROVIDES
  • Nature of the incident
  • Affected services
  • Types of data affected
  • Known or estimated scope
  • Mitigation performed
  • Relevant contact information
  • Additional updates as investigation continues
Initial notifications are not delayed solely because every detail is not yet known.
21 · SECURITY INCIDENT COOPERATION

Reasonable assistance, proportionate scope.

  • Incident investigation
  • Customer risk assessment
  • Regulatory notification
  • Data-subject notification
  • Remediation

Assistance remains proportionate to the incident and the services provided.

22 · DATA LOCATION

Processing locations and residency.

The DPA identifies or references where Customer Personal Data may be processed. Regional or customer-specific residency options are defined in the Order Form, product documentation, DPA annex, or enterprise agreement.

No blanket residency promise
Residency claims are not made until the capability is technically available and contractually supported.
23 · RETENTION

Customer-controlled retention where supported.

Hayrok retains Customer Personal Data according to the customer agreement, product configuration, applicable retention settings, security requirements, legal obligations, and backup lifecycle. Different categories may have different retention periods.

  • Findings
  • Evidence
  • Reports
  • Audit logs
  • Telemetry
  • Authentication records
  • Nectar interaction records
24 · RETURN & DELETION

What happens when the service ends.

At termination or expiration, Hayrok returns or deletes Customer Personal Data according to the DPA, subject to applicable legal requirements and the technical lifecycle of backups.

DELETION WORKFLOW
Active systems Search indexes Caches Derived stores Backup expiration

Backups may be deleted through their normal lifecycle rather than immediate removal where appropriate. Data retained because of a legal obligation remains protected and limited to the required purpose.

25 · CUSTOMER EXPORTS

Reasonable opportunity to take your data.

Before termination, customers have a reasonable opportunity, where supported, to export eligible information:

  • Findings
  • Reports
  • Evidence packages
  • Asset information
  • Relevant configuration
  • Other supported customer records

Export capabilities reflect current product functionality rather than broad contractual promises.

26 · AUDIT & COMPLIANCE INFORMATION

Demonstrating Hayrok's controls.

  • Security documentation
  • Architecture information
  • Security questionnaire responses
  • Independent assurance reports when available
  • Penetration-test summaries where appropriate
  • Relevant policies
  • Subprocessor information

The DPA does not grant every customer unrestricted physical or technical audit access to production systems — a tiered model is more appropriate.

27 · AUDIT MODEL

Four levels, in order.

LEVEL 01
DOCS

Trust documentation

Customer reviews existing documentation on the Trust Center.

LEVEL 02
Q&A

Security review

Hayrok responds to reasonable questions during procurement or renewal.

LEVEL 03
ASSURE

Independent assurance

Where available, customers review independent reports or certifications.

LEVEL 04
AUDIT

Customer audit

Only where legally necessary and existing documentation is insufficient, subject to:

  • Reasonable notice
  • Confidentiality
  • Scope limitations
  • Security restrictions
  • No access to other customers' data
  • No unreasonable operational disruption
28 · PRIVATE RUNNER & CUSTOMER-CONTROLLED INFRASTRUCTURE

Shared data-protection responsibilities.

Where the customer deploys a Hayrok Customer Runner, Private Runner, or related component within customer-controlled infrastructure, responsibility is shared.

HAYROK MAY BE RESPONSIBLE FOR
  • Runner software
  • Work-request authentication
  • Platform authorization
  • Supported encryption
  • Application updates
  • Relevant platform logging
CUSTOMER MAY BE RESPONSIBLE FOR
  • Host infrastructure
  • Network configuration
  • Local credentials
  • OS security
  • Customer-controlled encryption keys
  • Local access
  • Environment configuration
  • Authorized validation targets
29 · CUSTOMER-MANAGED KEYS

Enterprise encryption control.

Where Customer-Managed Keys are supported, the Order Form or service documentation specifies:

  • Data classes covered
  • Key-management provider
  • Key ownership
  • Rotation requirements
  • Revocation behavior
  • Availability implications
  • Recovery considerations
Not universal
The DPA does not imply that customer-managed encryption applies to every data store unless that is technically true for the deployment.
30 · GOVERNMENT & LEGAL REQUESTS

Protecting customer information.

Subject to applicable law, Hayrok:

  • Validates the request
  • Limits disclosure to what is legally required
  • Notifies the affected customer where legally permitted
  • Challenges requests where appropriate and reasonably available
  • Documents relevant handling

Exact contractual language is reviewed by counsel, particularly because this may affect international-transfer assessments.

31 · SENSITIVE DATA

Data minimization is shared.

Customers should avoid submitting unnecessary sensitive information.

REQUIRES ADDITIONAL CONSIDERATION
  • Authentication secrets
  • Private keys
  • Passwords
  • Financial information
  • Government identifiers
  • Health information
  • Special-category personal data
Validation evidence redacts or minimizes sensitive fields where possible without undermining the security purpose.
32 · CUSTOMER CREDENTIALS

Credentials require stronger controls.

  • Encryption
  • Secret storage
  • Least privilege
  • Credential binding
  • Access restrictions
  • Rotation
  • Expiration
  • Auditability
Passwords, tokens, private keys
are not intentionally included in AI prompts or general evidence records unless an authorized workflow explicitly requires that processing.
33 · EVIDENCE & PRIVACY

Evidence can contain personal data.

  • Tenant isolation
  • Access control
  • Retention policy
  • Encryption
  • Evidence integrity
  • DPA obligations

AI-generated descriptions of evidence are derived information and do not replace the underlying source record.

34 · CONTROLLER DATA VS. CUSTOMER DATA

Two distinct categories.

PROCESSED FOR CUSTOMER

Customer Personal Data

Processed by Hayrok on the customer's behalf. Covered by the processor provisions of the DPA.

HAYROK BUSINESS RECORDS

Hayrok Account & Business Data

Information Hayrok processes for its own legitimate business purposes:

  • Customer contact records
  • Billing contacts
  • Contract administration
  • Service-security records
  • Business communications

Governed primarily by the Privacy Policy and applicable law.

This distinction prevents the DPA from incorrectly treating every piece of information associated with a customer as processor-controlled data.
35 · DPA ANNEXES

Four clear annexes.

ANNEX I

Processing details

  • Parties & roles
  • Subject matter
  • Duration
  • Purpose
  • Nature of processing
  • Categories of personal data
  • Categories of data subjects
  • Frequency
  • Retention
ANNEX II

Technical & organizational measures

  • Identity · authorization
  • Tenant isolation
  • Encryption
  • Network security
  • Secure development
  • Vulnerability management
  • Logging · incident response
  • Resilience
  • Personnel security
  • Evidence security
  • AI security
ANNEX III

Subprocessors

Either listed directly or incorporated by reference from the maintained Trust Center list where legally appropriate.

ANNEX IV

International transfers

  • EU SCC selections
  • UK Addendum
  • Transfer-related party details
  • Supervisory authority
  • Governing-law selections
37 · REQUEST AN EXECUTABLE DPA

Short form. No procurement gauntlet.

Tell us who's asking and what jurisdictions apply. We'll send an execution-ready package tailored to your review.

COMPANY INFORMATION
TRANSFER REQUIREMENTS (optional — select all that apply)
EU / EEA personal dataUK personal dataCalifornia personal informationOther U.S. state dataOther international processingNot sure
No agreement upload required. Start from Hayrok's standard terms — material customer-specific requirements are handled through Legal or Sales.
38 · DPA FAQ

Enterprise procurement questions.

Do all customers need a DPA?+
Not necessarily. A DPA is generally relevant where Hayrok processes personal data on behalf of a customer and applicable privacy law or the parties' contractual requirements call for processor terms.
Is the DPA part of the Hayrok agreement?+
Yes — the standard structure makes the DPA part of the governing customer agreement once properly incorporated or executed.
Does the DPA cover Nectar?+
Customer Personal Data processed through Nectar remains subject to the DPA where Hayrok acts as a Processor.
Does Hayrok use subprocessors?+
Yes. Hayrok uses vetted providers to operate parts of the service. Current applicable subprocessors are maintained through the Trust Center.
Does Hayrok support EU SCCs?+
Yes — the DPA incorporates the applicable EU Standard Contractual Clauses when required for covered transfers.
Does Hayrok support UK transfers?+
The DPA supports the applicable UK transfer mechanism, such as the UK Addendum to the EU SCCs, where required.
Where is customer data processed?+
Processing locations depend on the Hayrok service architecture, subprocessors, deployment model, and any contractual residency options. Current information is available through the Trust Center or customer agreement.
Can we use our own DPA?+
We encourage starting from the standard Hayrok DPA to speed review. Material customer-specific requirements can be discussed through Legal or Sales.
How does Hayrok handle privacy requests?+
Where Hayrok acts as Processor, it supports the relevant customer in fulfilling applicable data-subject requests according to the DPA. Individuals can also use the Privacy Request Center.
What happens to our data when we leave?+
Customer Personal Data is returned or deleted in accordance with the DPA, customer agreement, applicable law, and relevant backup lifecycle.

Need the DPA countersigned?

Send us your entity details and the agreement you are executing under, and our team will return a countersigned copy along with the current subprocessor list.