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Data Processing Addendum

Effective Date: May 4, 2026

This Data Processing Addendum is a business-customer draft for Apeonwheels Inc. and CloudPort. It should be reviewed by counsel before use with enterprise customers.

Roles

For individual consumer accounts, Apeonwheels Inc. generally acts as a controller/business for account, billing, support, security, and service operations.

For business customers that provide end-user personal data to CloudPort under a separate written agreement, Apeonwheels Inc. may act as a processor/service provider for specified processing activities.

Processing Subject

Account administration, subscription management, support, node status, diagnostics, security, billing, abuse prevention, and service delivery.

Categories of Data

Account identifiers, business contact information, billing metadata, device labels, usage metadata, security logs, support messages, and administrative audit logs.

Instructions

Apeonwheels Inc. will process customer personal data according to the agreement, this addendum, documented instructions, applicable law, and necessary service operations.

Confidentiality and Security

Apeonwheels Inc. will use reasonable technical and organizational safeguards and restrict access to personnel and subprocessors who need access for service delivery.

Subprocessors

Apeonwheels Inc. may use subprocessors listed in the Subprocessor List. Customers may subscribe to update notices when production systems are finalized.

Assistance

Where applicable and reasonably available, Apeonwheels Inc. will assist with data subject requests, security incidents, audits, and impact assessments.

Deletion and Return

At termination, Apeonwheels Inc. will delete or return customer personal data according to the agreement, subject to legal, accounting, security, and backup retention requirements.

International Transfers

Where required, the parties will use appropriate transfer mechanisms such as Standard Contractual Clauses or other lawful mechanisms.