Data Processing Agreement

APPENDIX 1

A. LIST OF PARTIES

Data exporter(s): ‍

‍Name : Customer (As set forth in the relevant Order Form).

‍Address: As set forth in the relevant Order Form.

Contact person’s name, position, and contact details: As set forth in the relevant Order Form.‍

‍Activities relevant to the data transferred under these Clauses: Recipient of the Services provided by Joist in accordance with the Agreement (as defined in Recital A of this DPA). ‍

‍Signature and date: Signature and date are set out in this DPA.‍

‍Role Controller/ Processor): Controller‍

‍Data importer(s): ‍

‍Name: Joist AI (As set forth at the beginning of this DPA)

‍Address: Joist Technologies, Inc. 8910 University Center Lane, Suite 400, San Diego, CA 92122.

Contact person’s name, position, and contact details: Rohan Jawali, CEO, Joist Technologies Inc.

‍‍Activities relevant to the data transferred under these Clauses: Provision of the Services to the Customer in accordance with the Agreement.‍

‍Signature and date: Signature and date are set out in this DPA.‍

‍Role (controller/processor): Processor.

APPENDIX 2

B. DESCRIPTION OF TRANSFER
‍Categories of data subjects whose personal data is transferred

‍Customer’s Authorized Users (as defined in the Agreement) of the Services.

‍Categories of personal data transferredName, Title, Role, Education/Qualifications/Past Experience/Career Summaries/Bios, Business contact details, Image, Gender Identification (i.e. pronouns), Language, Related person, Related URL, User ID, Username, hourly rates.

‍Sensitive data transferred (if applicable) and applied restrictions or safeguards that fully take into consideration the nature of the data and the risks involved, such as for instance strict purpose limitation, access restrictions (including access only for staff having followed specialized training), keeping a record of access to the data, restrictions for onward transfers or additional security measures.
‍No sensitive data collected.

‍The frequency of the transfer (e.g., whether the data is transferred on a one-off or continuous basis).
‍Continuous basis

‍Nature of the processing
‍Extracting the person’s information from past proposal documents and indexing and organization purposes, enabling fast and efficient retrieval.‍

‍Purpose(s) of the data transfer and further processing
‍The purpose of the transfer is to facilitate the performance of the Services more fully described in the Agreement pursuant to executed Order Forms.‍

‍The period for which the personal data will be retained, or, if that is not possible, the criteria used to determine that period
‍Personal data will be retained only for as long as is necessary to fulfil the purposes for which it was collected or in accordance with applicable data protection legislation.

‍‍For transfers to (sub-) processors, also specify subject matter, nature, and duration of the processing
‍The subject matter, nature, and duration of the Processing more fully described in the Agreement, Addendum, and accompanying order forms.

APPENDIX 3

TECHNICAL AND ORGANISATIONAL MEASURES INCLUDING TECHNICAL AND ORGANISATIONAL MEASURES TO ENSURE THE SECURITY OF THE DATA
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Description of the  technical and organisational security measures implemented by Joist AI as the data processor/data importer 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.


SECURITY

Security Management System

• ‍Organization. Joist AI designates qualified security personnel whose responsibilities include development, implementation, and ongoing maintenance of the Information Security Program.
• ‍Policies. Management reviews and supports all security related policies to ensure the security, availability, integrity and confidentiality of Customer Personal Data.  These policies are updated at least once annually.
• ‍Assessments. Joist AI engages a reputable independent third-party to perform risk assessments of all systems containing Customer Personal Data at least once annually.
• ‍Risk Treatment. Joist AI maintains a formal and effective risk treatment program that includes penetration testing, vulnerability management and patch management to identify and protect against potential threats to the security, integrity or confidentiality of Customer Personal Data.
• ‍Vendor Management. Joist AI maintains an effective vendor management program
• Incident Management. Joist AI reviews security incidents regularly, including effective determination of root cause and corrective action.
• Standards. Joist AI operates an information security management system that complies with the requirements of ISO/IEC 27001:2022 standard.

Personnel Security

• ‍Joist AI personnel are required to conduct themselves in a manner consistent with the company’s guidelines regarding confidentiality, business ethics, appropriate usage, and professional standards. Joist conducts reasonably appropriate background checks on any employees who will have access to client data under this Agreement, including in relation to employment history and criminal records, to the extent legally permissible and in accordance with applicable local labor law, customary practice and statutory regulations.
• ‍Personnel are required to execute a confidentiality agreement in writing at the time of hire and to protect Customer Personal Data at all times. Personnel must acknowledge receipt of, and compliance with, Joist’s confidentiality, privacy and security policies. Personnel are provided with privacy and security training on how to implement and comply with the Information Security Program. Personnel handling Customer Personal Data are required to complete additional requirements appropriate to their role (e.g., certifications). Joist’s personnel will not process Customer Personal Data without authorization.

Access Controls

• ‍Access Management. Joist AI maintains a formal access management process for the request, review, approval and provisioning of all personnel with access to Customer Personal Data to limit access to Customer Personal Data and systems storing, accessing or transmitting Customer Personal Data to properly authorized persons having a need for such access. Access reviews are conducted periodically to ensure that only those personnel with access to Customer Personal Data still require it.
• ‍Infrastructure Security Personnel. Joist AI has, and maintains, a security policy for its personnel, and requires security training as part of the training package for its personnel. Joist’s infrastructure security personnel are responsible for the ongoing monitoring of Joist’s security infrastructure, the review of the Services, and for responding to security incidents.
• Access Control and Privilege Management. Joist AI’s and Customer’s administrators and end users must authenticate themselves via a Multi-Factor authentication system or via a single sign on system in order to use the Services
• ‍Internal Data Access Processes and Policies – Access Policy. Joist AI’s internal data access processes and policies are designed to protect against unauthorized access, use, disclosure, alteration or destruction of Customer Personal Data. Joist designs its systems to only allow authorized persons to access data they are authorized to access based on principles of “least privileged” and “need to know”, and to prevent others who should not have access from obtaining access.  Joist requires the use of unique user IDs, strong passwords, two factor authentication and carefully monitored access lists to minimize the potential for unauthorized account use. The granting or modification of access rights is based on: the authorized personnel’s job responsibilities; job duty requirements necessary to perform authorized tasks; a need to know basis; and must be in accordance with Joist’s internal data access policies and training. Approvals are managed by workflow tools that maintain audit records of all changes. Access to systems is logged to create an audit trail for accountability. Where passwords are employed for authentication (e.g., login to workstations), password policies follow industry standard practices. These standards include password complexity, password expiry, password lockout, restrictions on password reuse and re-prompt for password after a period of inactivity

Data Center and Network Security

Data Centers

• Infrastructure. Joist AI has AWS as its data center.
• Resiliency. Multi-AZ deployments are enabled via AWS’s serverless architecture, ensuring high availability and fault tolerance. Additionally, Joist performs regular disaster recovery testing, including backup restoration exercises, with a business continuity plan in place
• Server Operating Systems. Joist AI operates within a customized application environment hosted on AWS, where all compute resources are securely configured and hardened in alignment with best practices. A rigorous code review process is implemented as part of the secure development lifecycle to ensure code quality and reduce vulnerabilities prior to deployment, thereby strengthening the security of services in production.
• Disaster Recovery. Joist AI is committed to maintaining uninterrupted service and data integrity through a robust Disaster Recovery and Incident Response program. Joist AI implements automated daily backups, multi-system data replication, and isolated storage to safeguard against data loss. Regular disaster recovery testing and a formal incident response plan—with defined roles and rapid escalation procedures are also implemented
• Security Logs. Joist AI’s systems have logging enabled to their respective system log facilities to support security audits and enable monitoring and detection of actual or attempted attacks or intrusions. Logging is enforced across the infrastructure, with logs securely stored and continuously monitored for anomalous activity.
• Vulnerability Management. Joist AI performs regular vulnerability scans on all infrastructure components of its production and development environment.  Vulnerabilities are remediated on a risk basis, with Critical security patches for all components installed as soon as commercially possible.

Networks and Transmission.

• Data Transmission. All transmissions within Joist AI’s production environments are secured using industry-standard Internet protocols, including HTTPS with TLS 1.2 or higher.
• External Attack Surface. Joist AI’s external attack surface is secured through a layered network security architecture within AWS. The production environment is hosted in isolated Virtual Private Clouds (VPCs), where traffic flow is tightly controlled using a combination of Security Groups and Network Access Control Lists (NACLs).
• Incident Response. Joist AI maintains formal incident response policies and procedures, including defined escalation paths, roles, and responsibilities to ensure swift and effective handling of security incidents. A range of communication channels and monitoring tools are actively observed for indicators of compromise. Upon detection of a suspected or confirmed incident, Joist’s security team initiates containment and mitigation actions, conducts root cause analysis, and documents the incident and resolution in accordance with its incident response plan.
• Encryption Technologies. Joist AI employs HTTPS encryption (TLS 1.2 or higher) to protect all data in transit across its services. In addition, data at rest is encrypted using AES-256 via AWS Key Management Service (KMS), ensuring strong protection for sensitive information both during transmission and while stored within AWS infrastructure.
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Data Storage, Isolation, Authentication, and Destruction.
Joist AI stores data in a multi-tenant environment on AWS RDS servers. Data, the Services database and file system architecture are replicated between multiple availability zones on AWS. Joist logically isolates the data of different customers. A central authentication system is used across all Services to increase uniform security of data. Joist ensures secure disposal of Client Data through the use of a series of data destruction processes.
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APPENDIX 4

LIST OF SUB-PROCESSORS

‍Please refer to https://trust.joist.ai/ for Joist AI’s list of sub-processors.