Data Processing Agreement (DPA)

Last updated:
March 19th, 2025

Wildfell Software LLC

1001 Wade Ave Ste 327

Raleigh, North Carolina,

USA

This Data Processing Agreement ("DPA") supplements the IGOR Subscription Agreement ("Agreement") between Wildfell Software LLC dba IGOR ("IGOR") and the Subscriber who has entered into the Agreement for the provision of Subscription Services by IGOR. This DPA applies where the Subscriber is acting as a “Controller” and IGOR is acting as a “Processor” under applicable Data Protection Law. The terms of this DPA are governed by the Agreement. In the event of any conflict between the DPA and the Agreement, the terms of the DPA shall prevail.

1. Definitions

Any capitalized term not defined in this DPA shall have the meaning given to it in the Agreement. To the extent that a capitalized term is defined in both this DPA and the Agreement or any related addendum, it will have the meaning given to it in this DPA for the purposes of this DPA only.

“Affiliate”

means any entity that directly or indirectly controls, is controlled by, or is under common control of a party. “Control”, for purposes of this definition, means direct or indirect ownership or control of more than 50% of the voting interests of a party;

“Agreement”

means the agreement between the Controller and the Processor for the provision of the Services;

“Controller”

means the Subscriber named in the Order Form signed when entering into the Agreement;

“Data Protection Law”

means all laws and regulations, including laws and regulations of the European Union, the European Economic Area, their member states and the United Kingdom, any amendments, replacements or renewals thereof, applicable to the processing of Personal Data, including where applicable the Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2020, the EU GDPR, the UK GDPR, the UK Data Protection Act 2018, the FADP, US State Privacy Laws and any applicable national implementing laws, regulations and secondary legislation relating to the processing of the Personal Data and the privacy of electronic communications, as amended, replaced or updated from time to time, including the Privacy and Electronic Communications Directive (2002/58/EC) and the Privacy and Electronic Communications (EC Directive) Regulations 2003 (SI 2003/2426);

“Data Subject”

shall have the same meaning as in Data Protection Law and includes a “Consumer” or “individual” as those terms are defined in US State Privacy Laws;

“DPA”

means this data processing agreement together with Exhibits A and B;

“EEA”

means the European Economic Area;

“EU 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, (General Data Protection Regulation);

“FADP”

means the Swiss Federal Act on Data Protection of the 1st of September 2023, and as amended from time to time;

“Personal Data”

shall have the same meaning as in Data Protection Law and includes “personally identifiable information,” as that term is defined in US State Privacy Laws;

“Processor”

means IGOR to the extent it processes Personal Data subject to Data Protection Laws;

“Restricted Transfer”

means:

(i) where the EU GDPR applies, a transfer of Personal Data via the Services from the EEA either directly or via onward transfer, to any country or recipient outside of the EEA not subject to an adequacy determination by the European Commission; and

(ii) where the UK GDPR applies, a transfer of Personal Data via the Services from the United Kingdom either directly or via onward transfer, to any country or recipient outside of the UK not based on adequacy regulations pursuant to Section 17A of the United Kingdom Data Protection Act 2018; and

(iii) a transfer of Personal Data via the Services from Switzerland either directly or via onward transfer, to any country or recipient outside of the EEA and/or Switzerland not subject to an adequacy determination by the European Commission;

“Services”

means all services and software applications and solutions provided to the Controller by the Processor under and as described in the Agreement, including, without limitation, the Subscription Services;

“SCCs”

means:

(i) where the EU GDPR applies, the standard contractual clauses annexed to the European Commission's Implementing Decision 2021/914 of 4 June 2021 on standard contractual clauses for the transfer of personal data to third countries published at https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32021D0914&from=EN, (“EU SCCs”); and

(ii) where the UK GDPR applies the international data transfer addendum to the EU SCCs adopted pursuant to Article 46(2)(c) of the UK GDPR and published at https://ico.org.uk/media/for-organisations/documents/4019539/international-data-transfer-addendum.pdf, as may be amended or replaced, (“UK SCCs”); and

(iii) where Personal Data is transferred from Switzerland to outside of Switzerland or the EEA, the EU SCCs as amended in accordance with guidance from the Swiss Data Protection Authority; (“Swiss SCCs”);

as they may be amended, superseded or replaced from time to time.

“Subprocessor”

means any third party (including the Processor’s Affiliates) engaged directly or indirectly by the Processor to process Personal Data under this DPA in the provision of the Services to the Controller;

“Subscriber Data”

means all data imported into the Services for the purpose of using the Services or facilitating use of the Services by the Subscriber or its Authorized Users, including, without limitation, User Content;

“Supervisory Authority”

means a governmental or government chartered regulatory body having binding legal authority over a party;

“UK GDPR”

means the EU GDPR as it forms part of the law of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018;

“US State Privacy Laws”

means the following US state data protection or privacy laws and regulations applicable to the party’s Processing of Personal Data: California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), Virginia Consumer Data Protection Act (VCDPA), Colorado Privacy Act (CPA), Connecticut Data Privacy Act (CTDPA), and Utah Consumer Privacy Act (UCPA) and the Connecticut Data Privacy Act (CTDPA), the Montana Consumer Data Privacy Act (MCDPA), Consumer Data Protection (Iowa CDPA), the Delaware Personal Data Privacy Act (DPDPA), the Nebraska Data Privacy Act (NDPA), the New Hampshire Expectation of Privacy Act (NHPA) and the New Jersey Act Concerning Online Services, Consumers, and Personal Data (NJDPA), in each case as may be amended or superseded from time to time.

2. Purpose

2.1 The Processor has agreed to provide the Services to the Controller in accordance with the terms of the Agreement. In providing the Services, the Processor shall process Subscriber Data on behalf of the Controller. Subscriber Data may include Personal Data. The Processor will process and protect such Personal Data in accordance with the terms of this DPA.

3. Scope

3.1 In providing the Services to the Controller pursuant to the terms of the Agreement, the Processor shall process Personal Data only to the extent necessary to provide the Services in accordance with the terms of the Agreement, this DPA and the Controller’s instructions documented in the Agreement and this DPA, as updated from time to time.

3.2 The Controller and Processor shall take steps to ensure that any natural person acting under the authority of the Controller or the Processor who has access to Personal Data does not process Personal Data except on the instructions from the Controller, unless required to do so by any Data Protection Law.

4. Processor’s Obligations

4.1 The Processor may collect, process or use Personal Data only within the scope of this DPA, as set out in more detail in Exhibit A of this DPA.

4.2 The Processor confirms that it shall process Personal Data on behalf of the Controller in accordance with the documented instructions of the Controller.

4.3 The Processor shall promptly inform the Controller, if in the Processor’s opinion, any of the instructions regarding the processing of Personal Data provided by the Controller, breach Data Protection Law.

4.4 The Processor shall ensure that all employees, agents, officers and contractors involved in the handling of Personal Data: (i) are aware of the confidential nature of the Personal Data and are contractually bound to keep the Personal Data confidential; (ii) have received appropriate training on their responsibilities as a data processor; and (iii) are bound by the terms of this DPA.

4.5 The Processor shall implement appropriate technical and organizational measures to protect Personal Data, taking into account: (i) the state of the art; (ii) the costs of implementation; (iii) the nature, scope, context and purposes of processing; and (iv) the risk of varying likelihood and severity for the rights and freedoms of natural persons.

4.6 The Processor shall implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including inter alia as appropriate: (i) the pseudonymization and encryption of Personal Data; (ii) the ability to ensure the on-going confidentiality, integrity, availability and resilience of processing systems and services; (iii) the ability to restore the availability and access to Personal Data in a timely manner in the event of a physical or technical incident; (iv) a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing. In determining the appropriate level of security, account shall be taken in particular of the risks that are presented by processing, in particular from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data transmitted, stored or otherwise processed.

4.7 The technical and organisational measures detailed in Exhibit B shall at all times be adhered to as a minimum security standard. The Controller accepts and agrees that the technical and organizational measures are subject to development and review and that the Processor may use alternative suitable measures to those detailed in the attachments to this DPA, provided such measures are at least equivalent to the technical and organizational measures set out in Exhibit B and appropriate pursuant to the Processor’s obligations in clauses 4.5 and 4.6 above.

4.8 The Controller acknowledges and agrees that, in the course of providing the Services to the Controller, it may be necessary for the Processor to access the Personal Data to respond to any technical problems or Controller queries and to ensure the proper working of the Services. All such access by the Processor will be limited to those purposes.

4.9 Taking into account the nature of the processing and the information available to the Processor, the Processor shall assist the Controller by having in place appropriate technical and organizational measures, insofar as this is possible, for the fulfillment of the Controller's obligation to respond to requests for exercising the Data Subject's rights and the Controller’s compliance with the Controller’s data protection obligations in respect of the processing of Personal Data.

4.10 The Processor may not: (i) sell Personal Data; (ii) retain, use, or disclose Personal Data for commercial purposes other than providing the Services under the terms of the Agreement; or (iii) retain, use, or disclose Personal Data outside of the terms of the Agreement.

5. Controller’s Obligations

5.1 The Controller represents and warrants that: (i) it shall comply with this DPA and its obligations under Data Protection Law; (ii) it has obtained any, and all, permissions and authorizations necessary to permit the Processor and Subprocessors, to execute their rights or perform their obligations under this DPA; and (iii) all Affiliates of the Controller who use the Services shall comply with the obligations of the Controller set out in this DPA.

5.2 The Controller shall implement appropriate technical and organizational measures to protect Personal Data, taking into account: (i) the state of the art; (ii) the costs of implementation; (iii) the nature, scope, context and purposes of processing; and (iv) the risk of varying likelihood and severity for the rights and freedoms of natural persons.

5.3 The Controller shall implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including inter alia as appropriate: (i) the pseudonymization and encryption of Personal Data; (ii) the ability to ensure the on-going confidentiality, integrity, availability and resilience of processing systems and services; (iii) the ability to restore the availability and access to Personal Data in a timely manner in the event of a physical or technical incident; (iv) a process for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing. In determining the appropriate level of security account shall be taken in particular of the risks that are presented by processing, in particular from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data transmitted, stored or otherwise processed.

5.4 The Controller acknowledges and agrees that some instructions from the Controller including the Processor assisting with audits, inspections, DPIAs or providing any assistance under this DPA, may result in additional fees. In such case the Processor shall notify the Controller of its fees for providing such assistance in advance and shall be entitled to charge the Controller for its reasonable costs and expenses in providing such assistance, unless agreed otherwise in writing.

6. Subprocessors

6.1 The Controller agrees that the Processor may engage Subprocessors in connection with the provision of the Services.

6.2 All Subprocessors who process Personal Data in the provision of the Services to the Controller shall comply with the obligations of the Processor set out in this DPA.

6.3 The Controller authorizes the Processor to use the Subprocessors included in the list of Subprocessors published at: https://www.igorlabapp.com/subprocessors to process the Personal Data. During the term of this DPA, the Processor shall provide the Controller with 30 days prior notification, via email, of any changes to the list of Subprocessors before authorizing any new or replacement Subprocessor to process Personal Data in connection with the provision of the Services.

6.4 The Controller may object to the use of a new or replacement Subprocessor, by notifying the Processor promptly in writing within fifteen (15) days after receipt of the Processor’s notice. If the Controller objects to a new or replacement Subprocessor, the Controller may terminate the Agreement with respect to those Services which cannot be provided by the Processor without the use of the new or replacement Subprocessor. The Processor will refund the Controller any prepaid fees covering the remainder of the term of the Agreement following the effective date of termination with respect to such terminated Services.

6.5 All Subprocessors who process Personal Data shall comply with the obligations of the Processor set out in this DPA. The Processor shall prior to the relevant Subprocessor carrying out any processing activities in respect of the Personal Data: (i) appoint each Subprocessor under a written contract containing materially the same obligations to those of the Processor in this DPA enforceable by the Processor; and (ii) ensure each such Subprocessor complies with all such obligations.

6.6 The Controller agrees that the Processor and its Subprocessors may make Restricted Transfers of Personal Data for the purpose of providing the Services to the Controller in accordance with the Agreement. The Processor confirms that such Subprocessors: (i) are located in a third country or territory recognized by the EU Commission or a Supervisory Authority, as applicable, to have an adequate level of protection; or (ii) have entered into the applicable SCCs with the Processor; or (iii) have other legally recognized appropriate safeguards in place.

7. Restricted Transfers

7.1 The parties agree that, when a transfer of Personal Data occurs between the Controller and the Processor or from the Processor to a Subprocessor which is a Restricted Transfer, it shall be subject to the applicable SCCs.

7.2 The parties agree that the EU SCCs shall apply to Restricted Transfers from the EEA. The EU SCCs shall be deemed entered into (and incorporated into this DPA by reference) and completed as follows:

(i) Module Two (Controller to Processor) shall apply where the Subscriber is a Controller of Personal Data and IGOR is processing Personal Data;

(ii) Module Three (Processor to Processor) shall apply where IGOR is a Processor of Personal Data and IGOR uses a Subprocessor to process the Personal Data;

(iii) Module Four (Processor to Controller) shall apply where IGOR is processing Personal Data and the Subscriber is not subject to the EU GDPR or UK GDPR;

(iv) In Clause 7 of the EU SCCs, the optional docking clause shall not apply;

(v) In Clause 9 of the EU SCCs, Option 2 applies, and the time period for giving notice of Subprocessor changes shall be as set out in clause 6.3 of this DPA;

(vi) In Clause 11 of the EU SCCs, the optional language shall not apply;

(vii) In Clause 17 of the EU SCCs, Option 1 applies and the EU SCCs shall be governed by Irish law;

(viii) In Clause 18(b) of the EU SCCs, disputes shall be resolved by the courts of Ireland;

(ix) Annex I of the EU SCCs shall be deemed completed with the information set out in Exhibit A of this DPA;

(x) Annex II of the EU SCCs shall be deemed completed with the information set out in Exhibit B of this DPA.

7.3 The parties agree that the EU SCCs as amended in clause 7.2 above, shall be adjusted as set out below where the FADP applies to any Restricted Transfer:

(i) The Swiss Federal Data Protection and Information Commissioner (“FDPIC”) shall be the sole Supervisory Authority for Restricted Transfers exclusively subject to the FADP;

(ii) Restricted Transfers subject to both the FADP and the EU GDPR, shall be dealt with by the EU Supervisory Authority named in Exhibit A of this DPA;

(iii) The term ’member state’ must not be interpreted in such a way as to exclude Data Subjects in Switzerland from the possibility of suing for their rights in their place of habitual residence (Switzerland) in accordance with Clause 18(c) of the EU SCCs;

(iv) Where Restricted Transfers are exclusively subject to the FADP, all references to the GDPR in the EU SCCs are to be understood to be references to the FADP;

(v) Where Restricted Transfers are subject to both the FADP and the EU GDPR, all references to the GDPR in the EU SCCs are to be understood to be references to the FADP insofar as the Restricted Transfers are subject to the FADP;

7.4 The parties agree that the UK SCCs shall apply to Restricted Transfers from the UK and the UK SCCs shall be deemed entered into (and incorporated into this DPA by reference), completed as follows:

(i) Table 1 of the UK SCCs shall be deemed completed with the information set out in Exhibit A of this DPA;

(ii) Table 2 of the UK SCCS shall be deemed completed with the information set out in clauses 7.2(i) – (viii) of this DPA;

(iii) Table 3 of the UK SCCs shall be deemed completed with the information set out in Exhibits A and B of this DPA; and

(iv) Either party may end the UK SCCs as set out in clause 19 of the UK SCCs.

7.5 If changes are made to the EU SCCs or UK SCCs in the future, the parties shall negotiate in good faith necessary amendments to the DPA and the Agreement to ensure compliance with applicable Data Protection Law.

7.6 In the event that any provision of this DPA contradicts directly or indirectly any SCCs, the provisions of the applicable SCCs shall prevail over the terms of the DPA.

7.7 Should countries other than those in the EEA, UK or Switzerland adopt cross-border data transfer clauses similar to the SCCs, the Controller and Processor agree to execute such clauses when necessary.

8. Data Subject Access Requests

8.1 The Controller may require correction, deletion, blocking and/or making available the Personal Data during or after termination of the Agreement. The Controller acknowledges and agrees that the Processor will process the request to the extent it is lawful and will reasonably fulfil such request in accordance with its standard operational procedures to the extent possible.

8.2 In the event that the Processor receives a request from a Data Subject in relation to Personal Data, the Processor will refer the Data Subject to the Controller unless otherwise prohibited by law. The Controller shall reimburse the Processor for all costs incurred resulting from providing reasonable assistance in dealing with a Data Subject request. In the event that the Processor is legally required to respond to the Data Subject, the Controller will fully cooperate with the Processor as applicable.

9. Audit

9.1 The Processor shall make available to the Controller all information reasonably necessary to demonstrate compliance with its processing obligations and allow for and contribute to audits and inspections.

9.2 If any audit is required and conducted under this DPA, it shall consist of examination of the most recent reports, certificates and/or extracts prepared by an independent auditor bound by confidentiality provisions similar to those set out in the Agreement. In the event that provision of the same is not deemed sufficient in the reasonable opinion of the Controller, the Controller may conduct a more extensive audit which shall be: (i) at the Controller’s expense; (ii) limited in scope to matters specific to the Controller and agreed in advance; (iii) carried out during the Processor’s usual business hours and upon reasonable notice which shall be not less than 4 weeks unless an identifiable material issue has arisen; and (iv) conducted in a way which does not interfere with the Processor’s day-to-day business.

9.3 This clause shall not modify or limit the rights of audit of the Controller, instead it is intended to clarify the procedures in respect of any audit undertaken pursuant thereto.

10. Personal Data Breach

10.1 The Processor shall notify the Controller without undue delay after becoming aware of (and in any event within 72 hours of discovering) any breach of security leading to the accidental or unlawful destruction, loss, alteration or unauthorized disclosure or access to any Personal Data (“Personal Data Breach”).

10.2 In the event of a Personal Data Breach, the Processor shall take all commercially reasonable measures to secure the Personal Data, to limit the effects of any Personal Data Breach, and to assist the Controller in meeting the Controller’s obligations under applicable law.

11. Compliance, Cooperation, and Response

11.1 The Processor will notify the Controller promptly of any request or complaint regarding the processing of Personal Data, which adversely impacts the Controller, unless such notification is not permitted under applicable law or a relevant court order.

11.2 The Processor may make copies of and/or retain Personal Data in compliance with any legal or regulatory requirement including, but not limited to, retention requirements.

11.3 The Processor shall reasonably assist the Controller in meeting the Controller’s obligation to carry out data protection impact assessments (DPIAs), taking into account the nature of the processing and the information available to the Processor.

11.4 The Controller shall notify the Processor within a reasonable time, of any changes to applicable data protection laws, codes or regulations which may affect the contractual duties of the Processor. The Processor shall respond within a reasonable timeframe in respect of any changes that need to be made to the terms of this DPA or to the technical and organizational measures to maintain compliance. If the Processor is unable to accommodate necessary changes, the

Controller may terminate the part or parts of the Services which give rise to the non-compliance. To the extent that other parts of the Services provided are not affected by such changes, the provision of those Services shall remain unaffected.

11.5 The Controller and the Processor and, where applicable, their representatives, shall cooperate, on request, with a Supervisory Authority in the performance of their respective obligations under this DPA and Data Protection Law.

12. Liability

12.1 The limitations on liability set out in the Agreement apply to all claims made pursuant to any breach of the terms of this DPA.

12.2 The parties agree that the Processor shall be liable for any breaches of this DPA caused by the acts and omissions or negligence of its Subprocessors to the same extent the Processor would be liable if performing the services of each Subprocessor directly under the terms of the DPA, subject to any limitations on liability set out in the terms of the Agreement.

12.3 The parties agree that the Controller shall be liable for any breaches of this DPA caused by the acts and omissions or negligence of its Affiliates as if such acts, omissions or negligence had been committed by the Controller itself.

12.4 The Controller shall not be entitled to recover more than once in respect of the same loss.

13. Term and Termination

13.1 The Processor shall only process Personal Data for the term of the DPA. The term of this DPA shall commence on the Effective Date of the Agreement and this DPA shall terminate automatically together with termination or expiry of the Agreement.

14. Deletion and Return of Personal Data

14.1 The Processor shall at the choice of the Controller, upon receipt of a written request received within 30 days of the end of the provision of the Services, delete or return Personal Data to the Controller. The Processor shall retain Personal Data in its systems for 12 months after the effective date of termination of the Agreement or deactivation of the Controller’s primary account, unless applicable law or regulations require storage of the Personal Data after termination for a different period of time.

15. General

15.1 This DPA sets out the entire understanding of the parties with regards to the subject matter herein.

15.2 Should a provision of this DPA be invalid or become invalid then the legal effect of the other provisions shall be unaffected. A valid provision is deemed to have been agreed which comes closest to what the parties intended commercially and shall replace the invalid provision. The same shall apply to any omissions.

15.3 Subject to any provision of the SCCs to the contrary, this DPA shall be governed by the choice of law, jurisdiction, and venue provisions specified in the Agreement.

15.4 The parties agree that this DPA is incorporated into and governed by the terms of the Agreement.

Exhibit A

List of Parties, Description of Processing and Transfer of Personal Data, Competent Supervisory Authority

A. LIST OF PARTIES

The Exporter: means the Subscriber.

Contact person’s name, position and contact details:	As provided by the Subscriber in its account and used for notification and invoicing purposes.
Activities relevant to the data transferred under the SCCs:	Use of the Services.
Signature and date:	By entering into the Agreement, the Exporter is deemed to have signed the SCCs incorporated into this DPA and including their Annexes, as of the Effective Date of the Agreement.
Role:	Controller.
Name of Representative (if applicable):	Any UK or EU representative named in the Exporter’s privacy policy.

The Importer: means Wildfell Software LLC dba IGOR

Contact person’s name, position and contact details:	Anika Weber, DPhil; CEO; aweber@igorlabapp.com
Activities relevant to the data transferred under the SCCs:	The provision of cloud computing solutions to the Exporter under which the Importer processes Personal Data upon the instructions of the Exporter in accordance with the terms of the Agreement.
Signature and date:	By entering into the Agreement, the Importer is deemed to have signed the SCCs, incorporated into this DPA, including their Annexes, as of the Effective Date of the Agreement.
Role:	Processor.
Name of Representative (if applicable):	Our EU and UK Representative is: Data Protection Representative Limited (trading as DataRep), 77 Camden Street Lower, Dublin, D02 XE80, Ireland. If you wish to raise a question please contact datarequest@datarep.com, quoting “IGOR” in the subject line.

В. DESCRIPTION OF PROCESSING AND TRANSFERS

Categories of Data Subjects:

Employees, agents, advisors, consultants, freelancers of the Controller (who are natural persons):

The "Super Admin" who represents the Subscriber/Primary Account Holder and controls the Primary account on the Subscriber’s behalf.

Individuals authorized by the Controller to access or use the Services in accordance with the terms of the Agreement:

Controller’s employees, agents, or freelancers,
External research collaborators, advisors, or consultants, such as:
- Subject matter experts engaged by the Controller as advisors or consultants, such as regulatory specialists, data scientists, bioinformaticians, or industry experts providing technical or strategic guidance
- Clients of the Controller, including biotechnology or pharmaceutical companies, contract research organizations (CROs), and other industry partners, engaged in joint research or contracted projects, and their employees.
- Academic research groups, including university laboratories, principal investigators, and affiliated researchers collaborating on shared studies or grants
- Any other natural person whom the Controller invites to join the Controller’s primary account and to access or use the Services in accordance with the terms of the Agreement.

(each an “Authorized User”)

Other individuals to the extent identifiable in the context of emails or their attachments, or in archiving content.

Categories of Personal Data:

The Controller and its Authorized Users, may submit Personal Data to the Services, the extent of which is determined and controlled by the Controller. The Personal Data includes but is not limited to:

Personal details, including first name, surname, initial, email addresses, telephone number and company name of Authorized Users of the Services.
Unique identifiers such as username, initial, and password.
Foto or avatar (optional)
IP address
Personal Data derived from an Authorized User’s use of the Services such as records and business intelligence information.
Personal Data within email and messaging content which identifies or may reasonably be used to identify individuals.
Metadata including sent, to, from, date, time, subject, which may include Personal Data.
Geolocation data based upon IP address.
Research data.
Data concerning education and profession.
File attachments that may contain Personal Data.
Survey, feedback, and assessment messages.
Information offered by Authorized Users of the Services as part of support enquiries.
Other data added by the Controller or Authorized Users from time to time.

Sensitive Data:

Sensitive data means the following special categories of Personal Data:

Personal Data revealing racial or ethnic origin
political opinions,
religious or philosophical beliefs
trade union membership
genetic data if it can be linked to an identifiable individual
biometric data for the purpose of uniquely identifying a natural person
data concerning health or data concerning a natural person's sex life or sexual orientation
personal data relating to criminal convictions and offenses

Subscribers and Authorized Users may upload only pseudonymized sensitive data, and only under the following strict conditions:

The pseudonymization key (i.e., the mapping between pseudonyms and real identities) must be stored separately by the Subscriber or Authorized User, entirely outside of IGOR’s infrastructure. UNDER NO CIRCUMSTANCES MAY THE RE-IDENTIFICATION KEY BE STORED WITHIN IGOR’S SYSTEM OR ANY SYSTEM UNDER IGOR’S CONTROL.

This exception applies only to pseudonymized data concerning:
- Ethnicity
- Genetic data
- Health data

No other categories of sensitive data shall be processed, transferred, or stored within IGOR.

Emails and file attachments containing sensitive data remain prohibited, unless they meet the pseudonymization conditions outlined above.

The frequency of the processing and transfer:

Continuous basis for the duration of the Agreement.

Nature of the processing:

Processing operations include but are not limited to:

Processing of research data and information about how and when users performed experiments, summaries and analysis of the resulting data, raw data files, images of observations/data, inventory and sample information, an audit trail of user activity (who made changes to the contents and when), digital signatures for review and approval workflows (e.g. for SOP management), comments left by users during the review/approval workflows (reviewer comments) and timestamps of any review activities (approval/rejection).

Purpose(s) of the data transfer and further processing:

Personal Data is transferred to sub-contractors who need to process some of the Personal Data in order to provide their services to the Processor as part of the Services provided by the Processor to the Controller.

The frequency of the processing and transfer:

Unless agreed otherwise in writing, for the duration of the Agreement, subject to clause 14 of the DPA.

For transfers to (Sub)processors, also specify subject matter, nature and duration of the processing:

The Subprocessor list published at: https://www.igorlabapp.com/subprocessors sets out the Personal Data processed by each Subprocessor and the services provided by each Subprocessor.

C. COMPETENT SUPERVISORY AUTHORITY

Identify the competent supervisory authority/ies (e.g. in accordance with Clause 13 of the SCCs):

Where the EU GDPR applies, the Irish Data Protection Authority - Data Protection Commission, (DPC).
Where the UK GDPR applies, the UK Information Commissioner's Office, (ICO).
Where the FADP applies, the Swiss Federal Data Protection and Information Commissioner, (FDPIC).

Exhibit B

Technical and Organizational Security Measures

(Including Technical and Organizational Measures to Ensure the Security of Data)

Below is a description of the technical and organizational measures implemented by the Processor (including any relevant certifications) to ensure an appropriate level of security, taking into account the nature, scope, context and purpose of the processing, and the risks for the rights and freedoms of natural persons.

Where applicable this Exhibit B will serve as Annex II to the SCCs.

Contact Us

If you have any questions about this Data Processing Agreement, or would like to receive a copy of this DPA in PDF format, please contact us at: support@igorlabapp.com