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Trust & Legal Center DRAFT FOR REVIEW · v1.0

Data Processing Addendum

This is a version 1.0 draft prepared for review. It reflects our verified technical and data-protection practices but is pending final management and legal approval. Some sections contain items still under management or legal review and should not be relied upon as final policy.

This addendum will govern the processing of personal data on behalf of customers acting as data controllers.

Effective date: 31 August 2026 · Version v1.0

Scope

This addendum applies where EDUMOVIA processes personal data on behalf of a customer (the controller) in the course of providing the platform. It forms part of the main service agreement.

Roles

The customer is the data controller and determines the purposes of processing. EDUMOVIA acts as processor and processes personal data only on documented instructions from the controller.

Security measures

EDUMOVIA applies tenant isolation, encryption of secrets, role-based access control, and personal-data scanning. AI features operate fail-closed and within an approved allowlist.

Sub-processing

The controller authorises EDUMOVIA to engage the sub-processors listed on the Sub-processors page. EDUMOVIA remains responsible for their compliance and will give notice of material changes.

International transfers and assistance

Where personal data is transferred internationally, appropriate safeguards are applied. EDUMOVIA assists the controller with data-subject requests, breach notification and, on termination, deletion or return of data. Final terms are subject to legal review.

Certain items marked [MANAGEMENT INPUT REQUIRED] in the text (supervisory authority contact details, data protection / privacy officer, and jurisdiction-specific legal points) are being finalized by EDUMOVIA management and legal counsel and will be updated in a subsequent revision.

For questions about our legal and data protection practices, please contact us.

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