Data Processing Agreement

This Data Processing Agreement (this “DPA”) is entered into by and between:

The Customer

(hereinafter “Customer”)

and

Pigeonhole Early Years Ltd, 12 Cooper Road, Bristol, United Kingdom

(hereinafter “Pigeonhole”)

(each a “Party” and collectively the “Parties”).

This DPA governs Pigeonhole’s processing of personal data on behalf of the Customer.

This DPA is effective as of the date of the Agreement.

1. Definitions

“Agreement” means the main agreement (terms and conditions and Pigeonhole Offer) entered into between the Customer and Pigeonhole as amended from time to time in accordance with its terms;

“Application Log” means the log used for storing access to Customer Data;

“Applicable Data Protection Laws” means laws and regulations applicable to Pigeonhole’s Processing of Personal Data under the Agreement, including but not limited to UK Data Protection Laws;

“Authorised Sub-Processors” means the Sub-Processors set out in Clause 6.2 as may be amended from time to time;

“Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the Processing of Personal Data;

“Customer Data” means the Personal Data regarding individuals made available to Pigeonhole by or on behalf of the Customer, pursuant to the Agreement for Processing to provide the Services;

“Customer Point of Contact” has the meaning given in Clause 16.3;

“Data Breach” has the meaning given in Clause 11.1;

“Data Centres” means the data centres used for hosting and storing of Customer Data on the Pigeonhole Platform;

“Data Subject Request” has the meaning given in Clause 10.1;

“DPA” means this Data Processing Agreement, including any schedules attached or referred to and including any future written amendments and additions (as applicable);

“Personal Data” means “personal data”, “personal information”, “personally identifiable information” or similar term defined in Applicable Data Protection Laws;

“Process” and inflections thereof means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated 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 a natural or legal person, public authority, agency or other body which Processes Personal Data on behalf of the Controller;

“Services” means the Pigeonhole Platform services described and provided under the Agreement and in accordance with this Data Processing Agreement;

“Sub-Processor” has the meaning given in Clause 6.1;

“UK Data Protection Laws” means all applicable privacy and data protection laws relating to the processing of Personal Data and the privacy of electronic communications including the UK GDPR, Data Protection Act 2018, the Privacy and Electronic Communications Directive (2002/58/EC) and the Privacy and Electronic Communications (EC Directive) Regulations 2003 (SI 2003/2426) and any laws that replace, extend, re-enact, consolidate or amend any of the foregoing;

“UK GDPR” means the GDPR as amended and incorporated into UK law under the European Union (Withdrawal) Act 2018;

“UK” means the United Kingdom;

“Transfer Mechanism” means the Standard Contractual Clauses approved by the European Commission Decision of 4 June 2021 (processor to processor) as amended from time to time, the International Data Transfer Agreement (“IDTA”) issued by the Information Commissioner’s Office under Section 119A of the Data Protection Act 2018 (effective from 21 March 2022), and/or the International Data Transfer Addendum (“Addendum”) issued by the Information Commissioner’s Office under Section 119A of the Data Protection Act 2018 (effective from 21 March 2022).

The terms “Personal Data Breach” and “Supervisory Authority” shall have the same meaning as in the Applicable Data Protection Laws.

All capitalized terms not otherwise defined herein shall have the meaning set out in the Agreement.

Any reference to writing or written includes email.

2. Background

2.1. The Parties have entered into the Agreement, where the Customer has engaged Pigeonhole to provide the Services. This DPA is incorporated by reference into the Agreement.

2.2. For the purposes of providing the Services under the Agreement, Pigeonhole will Process Customer Data throughout the Term of this DPA. This DPA applies to any and all activities associated with the Agreement, in whose scope Pigeonhole’s employees or agents Process the Customer Data on behalf of the Customer as set out in Clause 3.

3. Roles and Responsibilities

3.1. The parties agree that the Customer is the Controller of the Customer Data and Pigeonhole is the Processor of the Customer Data, except where Pigeonhole acts as a Controller Processing Customer Data in accordance with Clause 2.3.

3.2. The Customer as Controller instructs Pigeonhole to perform the Processing activities detailed in this DPA. The Customer will, subsequently, be entitled to, in writing or in a machine-readable format (in text form), modify, amend or replace any individual instructions by issuing such instructions to the point of contact designated by Pigeonhole. Instructions not foreseen in or covered by this DPA must be treated as requests for changes to the DPA. The Customer must, without undue delay, confirm in writing or in text form any instruction issued orally.

3.3. Pigeonhole may Process some Customer Data for its own legitimate business purposes, as an independent Controller, solely when the Processing is strictly necessary and proportionate, for one of the following purposes:

a. Providing access to the Platform (usernames and passwords of Authorised Users Processed);

b. Invoicing, managing the Customer relationship and corresponding with the Customer (name, email address, phone number, title of Admin User and Staff User Processed);

c. Monitoring, preventing and detecting misuse or fraudulent activity on the Platform;

d. Analysing, developing and improving the Platform and services for the benefit of both the Customer and Pigeonhole, and collecting benchmarking data to provide insight into the usage of the Platform (data will be aggregated and pseudonymised, or anonymised where possible).

When acting as an independent Controller, Pigeonhole will not Process Customer Data for any purpose other than the above list of legitimate business purposes. Any such Processing activity will be further stipulated in the Pigeonhole Privacy Policy.

4. Scope and Specification of Processing

4.1. The subject matter and nature of Processing of Customer Data by Pigeonhole is the performance of the Services pursuant to the Agreement and the purposes set forth in this DPA. The Customer and/or its Authorised Users upload the Customer Data to the Platform, and the types of Customer Data Processed depend on the Customer use of the Services. The purpose of Processing, the types of Customer Data and categories of Data Subjects that may be Processed under this DPA is further specified in the table below:

Type of Customer Data	Purpose (subject matter) of processing	Categories of Data Subjects Affected
Basic data (such as name, date of birth, birthplace, NHS number, gender, languages, dietary considerations etc.)	Ensure that the Customer has all relevant information about the child to run the business and to comply with regulatory requirements.	Children
Sensitive data (such as religion, ethnicity, allergies, medical information, SEN details, safeguarding concerns, vaccines, medicines, injuries/accident reports)	Ensure that the Customer has all relevant information about the child, including any safeguarding needs, to run the business and to comply with regulatory requirements and legal obligations.	Children
Attendance data (such as sick days, holidays, sign in/out data etc.)	To store attendance data and create attendance reports.	Children
Activity data (such as details of learning or development activity, observations, next steps etc.)	To be able to digitally track the child’s activities, e. g. sleeping, trips, eating, learning, and to record observations and plan next steps.	Children
Photos and files	To share photos of children and other necessary files, that may contain Customer Data, with the parents/guardians. Employees may possibly be in photos.	Children, Employees
Contact Details (such as name, address, email address, phone number)	Ensure that the parents can be contacted.	Parents/guardians/other family member
Financial Information (such as bank account details, invoices etc.)	For the Customer to be able to store relevant financial information in one place, to then be able to issue invoices etc.	Parents/guardians/other family member
Employee Details (such as name, address, email address, phone number, date of birth, qualifications and certificates, next of kin information etc.)	To keep records of employees, to contact them and store emergency details, including compliance with DBS checks.	Customer Employees
Attendance data (sick days and holidays)	To store attendance data and create attendance reports.	Customer Employees
Any Customer Data or other personal data included in notes or shared in private or team messages via the Platform.	Necessary for the Customers to utilize the Platform features.	Customer Employees, Parents/guardians/other family members, children
Any Customer Data or other personal data shared with Pigeonhole Customer Advisory team	Necessary to provide support services.	Customer Employees, Parents/guardians/other family members, children
Certain payer information (name, email, address, payment method, last 4 digits of card number, expiration date, one-time payment or future payment set up) and any documentation containing personal data in relation to payment disputes.	Necessary to provide the in-app payment services, and to allow the payer to see and manage their payment methods, and assist with payment disputes.	Parents/guardians who make payments via the in-app payments feature.
Certain child and parent information (name, email, address, NI Number, birth certificate, copy of signature) and any documentation containing personal data in relation to funding forms.	Necessary to provide the in-app funding form services, and to allow the parent to see and manage their funding forms.	Parents/guardians who make use the funding forms feature.

4.2. The duration of Processing is for the period determined in accordance with the Agreement and DPA, including Clauses 8-9.

5. Pigeonhole’s Obligations

5.1. Compliance with documented instructions. Except where expressly permitted by the Applicable Data Protection Laws or as otherwise required by law, Pigeonhole will Process Customer Data as Processor only insofar as it is absolutely necessary for the purpose of the performance of the Agreement, and solely in accordance with the Customer’s instructions in this DPA and the Applicable Data Protection Laws.

5.2. Objection to instructions. If Pigeonhole believes that an instruction violates the Applicable Data Protection Laws, Pigeonhole will notify the Customer of such belief without undue delay. Pigeonhole is entitled to suspend performance on such instruction until the Customer confirms or modifies such instruction.

5.3. Technical and organisational measures. Pigeonhole is responsible for implementing technical and organisational measures to ensure the adequate protection of the Customer Data, which measures must fulfil the requirements of the Applicable Data Protection Laws and ensure ongoing security, confidentiality, integrity, availability and resilience of processing systems and Services. Such measures are described in Annex 1 of this DPA. Pigeonhole reserves the right to modify the measures and safeguards implemented, provided that the level of security is not less protective than initially agreed upon. In the event of considerable changes to the measures, Pigeonhole shall notify the Customer of the changes.

Pigeonhole warrants that the company fulfils its obligations under Applicable Data Protection Laws to implement a process for regularly testing, assessing, and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing.

5.4. Confidentiality. Pigeonhole will keep the Customer Data confidential. This obligation persists without time limitation and will survive the termination or expiration of the Agreement and this DPA. Pigeonhole warrants that the Customer Data is only disclosed to persons authorised to Process the Customer Data on a need-to-know basis (including employees). Pigeonhole warrants that all employees involved in Processing of the Customer Data and other such persons as may be involved in Processing within Pigeonhole’s scope of responsibility are prohibited from Processing Customer Data outside the scope of the Customer instructions. Furthermore, Pigeonhole warrants that any person entitled to Process the Customer Data has undertaken a commitment to confidentiality or is subject to an appropriate statutory obligation to confidentiality.

5.5. Deletion, correction or return of Customer Data. Pigeonhole must correct or erase Customer Data if so instructed by the Customer and permitted under Applicable Data Protection Laws. Where an erasure request relating to Customer Data, consistent with Applicable Data Protection Laws or a corresponding restriction of Processing is impossible, Pigeonhole will, based on the Customer’s instructions, and unless agreed upon differently in the Agreement, destroy or otherwise put out of use if so instructed, in compliance with Applicable Data Protection Laws, all Customer Data or return the same to the Customer.

5.6. Defence support. Where a Data Subject asserts any claims against the Customer as permitted by Applicable Data Protection Laws, Pigeonhole will provide all reasonable assistance to the Customer in defending against such claims.

6. The Customer’s Obligations

6.1. Compliance with Applicable Data Protection Laws. The Customer is solely responsible for compliance with the Applicable Data Protection Laws, including but not limited, to the lawfulness of disclosing Customer Data to Pigeonhole and the lawfulness of having the Customer Data Processed by Pigeonhole on behalf of the Customer. The Customer warrants that it is lawfully authorised to Process and disclose the Customer Data to Pigeonhole. The Customer is responsible for maintaining and updating its respective privacy policy, notices and statements, including to mention Pigeonhole in it as its’ Processor.

6.2. Technical and organisational measures. The Customer is familiar with the technical and organisational measures set out in Annex 1, and it shall be the Customer’s responsibility that such measures ensure a level of security appropriate to the risk.

6.3. Defence support. Clause 5.6 above will apply, mutatis mutandis, to claims asserted by Data Subjects against Pigeonhole in accordance with Applicable Data Protection Laws.

7. Sub-Processing

7.1. Customer generally authorises Pigeonhole to appoint Sub-Processors in accordance with this Clause 6. The Customer acknowledges that Pigeonhole uses subcontractors that act as Sub-Processors on behalf of the Customer (“Sub-Processor”).

7.2. The Customer agrees that the following Sub-Processors are authorised for the purpose of the Processing of the Customer Data under this DPA, giving affirmative consent thereto:

Sub-Processor	Location of Processing	Description of subcontracted service	Customer Data Processed
Microsoft Azure	UK	Data Centre for hosting of the Platform, and collecting backups	All types and categories of Customer Data set out in Clause 3.1.
Resend	US	Email Communications	Name and email addresses of Authorised Users.
Stripe	US	Payment processing	Payer details (name, email, address, payment information)

7.3. Pigeonhole will, prior to the use of new Sub-Processor or a replacement of Sub-Processor, inform the Customer Point of Contact thereof with at least thirty (30) days’ prior written notice. The Customer is entitled to object in writing within ten (10) days after receipt of the notice from Pigeonhole, provided that such objection is based on reasonable grounds relating to data protection. Pigeonhole will evaluate the concerns and discuss possible solutions with the Customer. If these solutions are not reasonably possible in Pigeonhole’s discretion and the Customer continues to not approve the change (such approval may not be unreasonably withheld), the Customer may terminate the Agreement by giving fourteen (14) days’ written notice after having received Pigeonhole’s aforementioned decision. If the Customer does not terminate the Agreement within this timeframe, the Customer is deemed to have accepted the respective Sub-Processor. The Customer will receive a refund of any prepaid fees for the period following the effective date of termination in respect of such terminated services. No other claims of the Customer against Pigeonhole or of Pigeonhole against the Customer may be based on such termination.

7.4. The Customer accepts that an exchange of a Sub-Processor may be required in cases where the reason for the change is outside of Pigeonhole’s reasonable control (so-called emergency replacement). Pigeonhole will notify the Customer of such change. If the Customer reasonably objects to the use of this Sub-Processor, the Customer may exercise its right to terminate the Agreement as described in the Clause above.

7.5. Where Pigeonhole commissions Sub-Processors, Pigeonhole is responsible for ensuring that Pigeonhole’s obligations on data protection resulting from the Agreement and this DPA are, to the extent applicable to the nature of the services provided by such Sub-Processor, valid and binding upon subcontracting. Pigeonhole will enter into written agreement and will restrict the Sub-Processor (and any new Sub-Processors) access to Customer Data only to what is necessary to provide or maintain the Services in accordance with the Agreement and this DPA.

8. Location of Customer Data and Transfer to Third Countries

8.1. The location(s) of the Customer Data is set out in Clause 6.2 above.

8.2. Subject to Authorised Sub-processors in Clause 6.2, Pigeonhole will not transfer the Customer Data outside the UK without following the notification and objection process set out in Clause 6.3.

8.3. Pigeonhole may not transfer Customer Data outside the UK unless adequate protection of the Customer Data in the receiving country is secured. In the absence of an adequacy decision pursuant to Applicable Data Protection Laws, adequate protection in the receiving country (“third country”) shall be secured following the undertaking by Pigeonhole of a transfer risk assessment/transfer impact assessment (under UK / EU law as applicable to the Customer), through the implementation, and negotiation if applicable, of an agreement incorporating the appropriate Transfer Mechanism. If the Transfer Mechanism is insufficient to safeguard the transferred Customer Data, supplementary measures will be implemented to ensure the Customer Data is protected to the same standard as required under Applicable Data Protection Laws.

9. Customer Data Retention

9.1. Customer Data on the Pigeonhole Platform is retained until 60 days following the termination of the Agreement or until deletion is specifically requested by the Customer, or unless otherwise mentioned in Clause 8.2.

9.2. Customer Data processed by the following Authorised Sub-Processor, is generally retained as set out below:

a. Email logs from the email provider (Resend) are retained for 30 days. b. Microsoft Azure: Backup data is retained by Microsoft Azure for 90 days.

10. Term, Termination and Return or Deletion of Customer Data

10.1. This DPA and Processing will continue in force until 60 days after the termination of the Agreement, except where this DPA stipulates obligations beyond the term of the Agreement.

10.2. Within 60 days following the termination of the Agreement, Pigeonhole shall, upon the Customer’s instructions, return all Customer Data to the Customer or delete the same, unless required otherwise by the Applicable Data Protection Laws. The Customer Data shall be irreversibly deleted and cannot be retrieved and provided to the Customer after such 60 days. In specific cases designated by the Customer, Customer Data will be stored. The associated remuneration and protective measures will be agreed upon separately, unless already agreed upon in the Agreement.

11. Data Subject Request

11.1. Where a Data Subject asserts claims for rectification, erasure, objection or access (“Data Subject Request”) against Pigeonhole, and where Pigeonhole is able to correlate the Data Subject to the Customer, based on the information provided by the Data Subject, Pigeonhole will refer such Data Subject to contact the Customer directly.

11.2. Pigeonhole will, based upon the Customer’s instructions, support the Customer to the extent reasonably possible in fulfilling a Data Subject Request, where the Customer cannot do so without Pigeonhole’s assistance. Pigeonhole will not be liable in cases where the Customer fails to respond to the Data Subject’s request in total, correctly, or in a timely manner.

12. Data Breaches

12.1. Pigeonhole will notify the Customer without undue delay, and in any event within 48 hours of becoming aware of any unauthorised or unlawful Processing, alteration, loss, destruction or disclosure of, or damage or access to the Customer Data within Pigeonhole’s scope of responsibility, on any Sub-Processor that may be Processing Customer Data on its behalf (“Data Breach”). Pigeonhole will implement the measures necessary for securing Customer Data and for mitigating potential negative consequences for the Data Subject. Pigeonhole will coordinate such efforts with the Customer without undue delay.

12.2. Pigeonhole will support the Customer, to the extent reasonably possible and only where the Customer cannot do so without Pigeonhole’s assistance, in communicating Data Breaches to the affected Data Subjects and notifying Data Breaches to the Information Commissioner’s Office (ICO) as required by Applicable Data Protection Laws (provided that this support does not result in any breach of Pigeonhole’s confidentiality obligations towards third parties).

13. Data Protection Impact Assessment and Consultation with Supervisory Authorities

To the extent that the required information is available to Pigeonhole, and the Customer does not otherwise have access to the required information, Pigeonhole will, upon written request, provide reasonable assistance to the Customer with any data protection impact assessment, and prior consultations with the ICO or the extent required under Applicable Data Protection Laws.

14. Audits

14.1. Pigeonhole will on an annual basis undergo an independent external audit of information security and measures pursuant to this DPA. Pigeonhole will document Pigeonhole’s compliance with the technical and organisational measures agreed upon in this DPA by appropriate measures.

14.2. To the extent required under the Applicable Data Protection Laws and upon the Customer written request, Pigeonhole will provide the Customer with a summary of independent external audit report with sufficient information to enable the Customer to reasonably verify that Pigeonhole’s compliance with its obligations under this DPA, including that Pigeonhole has implemented the technical and organisational security measures described in Annex 1. The documentation is Pigeonhole’s confidential information and must be treated as such.

14.3. The Customer agrees to exercise its audit right by instructing Pigeonhole to share the audit report summary as described in clause 13.2 of this DPA. If the Customer reasonably concludes that an onsite audit is necessary to monitor the compliance with the technical and organisational measures in an individual case or compliance with this DPA, the Customer has the right to carry out respective onsite inspections in individual cases or to have them carried out by an auditor (that is no competitor of Pigeonhole) provided that the Customer informs Pigeonhole of this with at least 30 days notice and that such audits and inspections will be conducted (i) during regular business hours, and (ii) without disproportionately interfering with Pigeonhole’ business operations, (iii) upon prior reasonable notice and further consultation with Pigeonhole, (iv) all subject to (if not covered already by the Agreement) the execution of a confidentiality undertaking, in particular to protect the confidentiality of the technical and organisational measures and safeguards implemented.

14.4. In case of an onsite audit the Customer will bear its own expenses and compensate Pigeonhole the cost for its internal resources required to conduct the onsite audit (based on time and material according to the then current price list). If the audit reveals that Pigeonhole has breached its obligations under the Agreement or this DPA, Pigeonhole will promptly remedy the breach at its own cost and refund any payments made by the Customer towards the cost of Pigeonhole’s internal resources related to the Customer onsite audit.

15. Limitations of Liability

15.1. Pigeonhole is only liable for data protection losses, costs and expenses incurred as a result of i) Pigeonhole not complying with its obligations under this DPA; ii) Pigeonhole not complying with its Processor obligations under the Applicable Data Protection Laws; or iii) Pigeonhole’s Authorised Sub-Processor not complying with its data protection obligations (whether imposed under contract to Pigeonhole or by Applicable Data Protection Laws).

15.2. Each Party’s total aggregate liability arising out of or related to this DPA shall be subject to the exclusions and limitations of liability set forth in section 13 of the Agreement, unless otherwise agreed.

15.3. Subject to clause 14.1 and 14.2, each party (the “Indemnifying Party”) will indemnify the other Party (the “Indemnified Party”) against all claims and proceedings and all liability, loss, costs and expenses incurred by the Indemnified Party as a result of any claim made or brought by a Data Subject or other legal person in respect of any loss, damage or distress caused to them, or any fine imposed by a regulatory authority, as a result of any breach of the Applicable Data Protection Laws by the Indemnifying Party, its employees or agents, provided that the Indemnified Party gives to the Indemnifying Party prompt notice of such claim, full information about the circumstances giving rise to it, reasonable assistance in dealing with the claim and sole authority to manage, defend or settle it.

16. Obligations to Inform, Amendments & Data Protection Officer

16.1. Where the Customer Data becomes subject to search and seizure, an attachment order, confiscation during bankruptcy or insolvency proceedings, or similar events or measures by third parties while in Pigeonhole’s control, Pigeonhole will notify the Customer of such action without undue delay and follow the Customer’s reasonable instructions to preserve the confidentiality of the Customer Data. Pigeonhole will, without undue delay, notify to all pertinent parties in such action, that any Customer Data affected thereby is in the Customer’s sole property and area of responsibility, that Customer Data is at the Customer’s sole disposition, and that the Customer is the responsible body pursuant to the Applicable Data Protection Laws.

16.2. Clause 19 of the Agreement regarding Pigeonhole‘s right to amend the terms of the Agreement applies to changes to this DPA as this DPA forms part of the Agreement. For the avoidance of doubt, this does not apply to notifications of new Sub-Processors under Clause 6.3.

16.3. Pigeonhole has appointed a Data Protection Officer, who is responsible for matters relating to privacy and data protection. This Data Protection Officer can be reached at the following address:

Attn. Data Protection Officer David Mills dpo@pigeonholeapp.co.uk

17. Point of Contact

17.1. The Parties must notify each other of a point of contact for any issues related to data protection arising out of or in connection with the Agreement and this DPA.

17.2. For any such matters, the Customer can reach out to the Pigeonhole Security & Privacy Team at support@pigeonholeapp.com.

17.3. The Customer will inform Pigeonhole of its point of contact (“Customer Point of Contact”). Such contact shall be the main point of contact when Pigeonhole is assisting with Data Subject Requests, informing of Data Breaches, and informing the Customer of new Sub-Processors or amendments to this DPA.

18. Entire Agreement

18.1. Except as amended by this DPA, the Agreement will remain in full force and effect. Where individual regulations of this DPA are invalid or unenforceable, the validity and enforceability of the other regulations of this DPA shall not be affected.

18.2. In the event of any conflict or inconsistency among the following documents, the order of precedence will be: (i) any Transfer Mechanism, (ii) Annex 4 (Supplemental Clauses), (iii) this DPA, and (iv) the Agreement.

19. Precedence, Governing Law & Dispute Resolution

Section 24 of the Agreement (Precedence, Governing Law and Dispute Resolution) shall apply to this DPA.

Annex 1 - Technical and Organisational Security Measures

Pigeonhole has in place certain technical and organisational security measures to ensure compliance with the Applicable Data Protection Laws. Those measures are set in place to prevent improper destruction, alteration, disclosure, access, and other improper form of processing of Customer Data. The measures form part of this Annex 1..

Annex 4 – Supplemental Clauses to the SCCs & UK Addendum

Personal Data will be encrypted both in transit and at rest using industry standard encryption technology.
Pigeonhole will resist, to the extent permitted by Law, any request under Section 702 of Foreign Intelligence Surveillance Act (“FISA”).
Pigeonhole will use reasonably available legal mechanisms to challenge any demands for data access through the national security process that it may receive in relation to Customer’s data.
No later than the date on which your acceptance of the DPA becomes effective, Pigeonhole will notify you of any binding legal demand for the Personal Data it has received, including national security orders and directives, which will encompass any process issued under Section 702 of FISA, unless prohibited under Law.
Pigeonhole will ensure that its data protection officer has oversight of Pigeonhole’s and its Affiliates’ approach to international data transfers.