Data Processing Addendum

Last Updated February 9^th, 2026

JUNIOR DATA PROCESSING AGREEMENT

This Data Processing Agreement (“DPA”) amends and forms part of the written agreement between SAMO C, Inc (trading as “Junior”) with EIN 92-0441280 (“Company”) and the undersigned Customer(“Customer”)titled Junior Cloud Services Agreement (the “Agreement”). This DPA amends the terms and forms part of the Agreement or other agreement between Customer and Company governing the access to and use of Services (collectively, the “Master Agreement”).

1. Definitions

   1. In this DPA:

      1. “Controller”, “Data Subject”, “Personal Data”, “Personal Data Breach”, “Processing”, “Processor”, and “Supervisory Authority” have the meaning given to them in Data Protection Law;

      2. “Customer Personal Data” means Personal Data Processed by Company as a Processor on behalf of Customer or Third Party Controller;

      3. “Data Protection Law” means the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and the e-Privacy Directive 2002/58/EC (as amended by Directive 2009/136/EC), their national implementations in the European Economic Area (“EEA”), including the European Union, and all other data protection laws of the EEA, the United Kingdom (“UK”), and Switzerland, each as applicable, and as may be amended or replaced from time to time;

      4. “Data Subject Rights” means Data Subjects’ rights to information, access, rectification, erasure, restriction, portability, objection, the right to withdraw consent, and the right not to be subject to automated individual decision-making in accordance with Data Protection Law;

      5. “International Data Transfer” means any disclosure of Customer Personal Data by an organization subject to Data Protection Law to another organization located outside the EEA, the UK, or Switzerland;

      6. “Services” means the services provided by Company to Customer under the Agreement;

      7. “Subprocessor” means a Processor engaged by Company to Process Customer Personal Data;

      8. “SCCs” means the clauses annexed to the EU Commission Implementing Decision 2021/914 of June 4, 2021 on standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council as amended or replaced from time to time;

      9. “Third-Party Controller” means a Controller for which Customer is a Processor; and

      10. “UK Addendum” means the addendum to the SCCs issued by the UK Information Commissioner under Section 119A(1) of the UK Data Protection Act 2018 (version B1.0, in force March 21, 2022).

2. Capitalized terms used but not defined herein have the meaning given to them in the Agreement.

3. Scope

   1. This DPA applies to the Processing of Customer Personal Data by Company subject to Data Protection Law to provide the Services.

   2. The subject matter, nature and purpose of the Processing, the types of Customer Personal Data and categories of Data Subjects are set out in Annex I, which is an integral part of this DPA.

   3. Customer is a Controller and appoints Company as a Processor on behalf of Customer. Customer is responsible for compliance with the requirements of Data Protection Law applicable to Controllers.

   4. If Customer is a Processor on behalf of a Third-Party Controller, then Customer: is the single point of contact for Company; must obtain all necessary authorizations from such Third-Party Controller; and undertakes to issue all instructions and exercise all rights on behalf of such other Third-Party Controller.

4. Instructions

   1. Company will Process Customer Personal Data to provide the Services and in accordance with Customer’s documented instructions.

   2. The Controller’s instructions are documented in this DPA, the Agreement, and any applicable statement of work.

   3. Customer may reasonably issue additional instructions as necessary to comply with Data Protection Law. Company may charge a reasonable fee to comply with any additional instructions.

   4. Unless prohibited by applicable law, Company will inform Customer if Company is subject to a legal obligation that requires Company to Process Customer Personal Data in contravention of Customer’s documented instructions.

5. Personnel

   1. Company will ensure that all personnel authorized to Process Customer Personal Data are subject to an obligation of confidentiality.

6. Security and Personal Data Breaches

   1. Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of Processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, Company will implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including the measures listed in Annex II.

   2. Customer acknowledges that the security measures in Annex II are appropriate in relation to the risks associated with Customer’s intended Processing and will notify Company prior to any intended Processing for which Company’s security measures may not be appropriate.

   3. Company will notify Customer without undue delay after becoming aware of a Personal Data Breach involving Customer Personal Data. If Company’s notification is delayed, it will be accompanied by reasons for the delay.

7. Subprocessing

   1. Customer hereby authorizes Company to engage Subprocessors. A list of Company's current Subprocessors is included in Annex III.

   2. Company will enter into a written agreement with Subprocessors which imposes the same obligations as required by Data Protection Law.

   3. Company will notify Customer prior to any intended change to Subprocessors. Customer may object to the addition of a Subprocessor based on reasonable grounds relating to a violation of Data Protection Law by providing written notice detailing the grounds of such objection within thirty (30) days following Company’s notification of the intended change. Customer and Company will work together in good faith to address Customer’s objection.

8. Assistance

   1. Taking into account the nature of the Processing, and the information available to Company, Company will assist Customer, including, as appropriate, by implementing technical and organizational measures, with the fulfillment of Customer’s own obligations under Data Protection Law to: comply with requests to exercise Data Subject Rights; conduct data protection impact assessments, and prior consultations with Supervisory Authorities; and notify a Personal Data Breach.

   2. Company may charge a reasonable fee for assistance under this Section 7. If Company is at fault, Company and Customer shall each bear their own costs related to assistance.

9. Audit

   1. Upon reasonable request, Company must make available to Customer all information necessary to demonstrate compliance with the obligations of this DPA and allow for and contribute to audits, including inspections, as mandated by a Supervisory Authority or reasonably requested no more than once per year by Customer, and performed by an independent auditor as agreed upon by Customer and Company. The foregoing shall only extend to those documents and facilities relevant and material to the Processing of Customer Personal Data and shall be conducted during normal business hours and in a manner that causes minimal disruption.

   2. Company will inform Customer if Company believes that Customer's instruction under Section 8.1 infringes Data Protection Law. Company may suspend the audit or inspection or withhold requested information until Customer has modified or confirmed the lawfulness of the instructions in writing.

   3. Customer bears all costs related to an audit initiated by the Customer.

10. International Data Transfers

    1. Customer hereby authorizes Company to perform International Data Transfers to any country deemed to have an adequate level of data protection by the European Commission or the competent authorities, as appropriate; on the basis of adequate safeguards in accordance with Data Protection Law; or pursuant to the SCCs and the UK Addendum referred to in Sections 9.2 and 9.3.

    2. By signing this DPA, Company and Customer conclude Module 2 (controller-to-processor) of the SCCs and, to the extent Customer is a Processor on behalf of a Third-Party Controller, Module 3 (Processor-to-Subprocessor) of the SCCs, which are hereby incorporated and completed as follows: the “data exporter” is Customer; the “data importer” is Company; the optional docking clause in Clause 7 is implemented; Option 2 of Clause 9(a) is implemented and the time period therein is specified in Section 6.3 above; the optional redress clause in Clause 11(a) is struck; Option 1 in Clause 17 is implemented and the governing law is the law of Ireland, the courts in Clause 18(b) are the Courts of Ireland, Annex I and II to Module 2 and 3 of the SCCs are Annex I and II to this DPA respectively. For International Data Transfers from Switzerland: (i) Data Subjects who have their habitual residence in Switzerland may bring claims under the SCC’s before the courts of Switzerland.

    3. By signing this DPA, Company and Customer conclude the UK Addendum, which is hereby incorporated and applies to International Data Transfers outside the UK. Part 1 of the UK Addendum is completed as follows: (i) in Table 1, the “Exporter” is Customer and the “Importer” is Company, their details are set forth in this DPA, and the Agreement; (ii) in Table 2, the first option is selected and the "Approved EU SCCs" are the SCCs referred to in Section 9.2 of this DPA; (iii) in Table 3, Annexes 1 (A and B) and II to the "Approved EU SCCs" are Annex I and II respectively; and (iv) in Table 4, both the "Importer" and the “Exporter” can terminate the UK Addendum.

    4. If Company’s compliance with Data Protection Law applicable to International Data Transfers is affected by circumstances outside of Company’s control, including if a legal instrument for International Data Transfers is invalidated, amended, or replaced, then Customer and Company will work together in good faith to reasonably resolve such non-compliance. In the event that additional, replacement or alternative standard contractual clauses or UK standard contractual clauses are approved by Supervisory Authorities, Company reserves the right to amend the Agreement and this DPA by adding to or replacing, the standard contractual clauses or UK standard contractual clauses that form part of it at the date of signature in order to ensure continued compliance with Data Protection Law.

11. Notifications

    1. Customer will send all notifications, requests and instructions under this DPA to Company's Data Protection Officer via email to privacy@myjunior.ai

    2. Company will send all notifications under this DPA to Customer's contact at ___________

12. Termination and return or deletion

    1. This DPA is terminated upon the termination of the Agreement.

    2. Customer may request return of Customer Personal Data up to ninety (90) days after termination of the Agreement. Unless required or permitted by applicable law, Company will delete all remaining copies of Customer Personal Data within one hundred eighty (180) days after returning Customer Personal Data to Customer.

13. Limitation of Liability

Each party’s liability, taken together in the aggregate, arising out of or related to this DPA, whether in contract, tort, or under any other theory of liability, is subject to the “Limitation of Liability” section of the Agreement and other relevant provisions, and any reference to such section to the liability of a party means the aggregate liability of that party and all of its affiliates under the Agreement and all DPAs together. Nothing in this Section 13 is intended to restrict the rights of data subjects under Data Protection Law.

1. Applicable law and jurisdiction

This DPA is governed by the laws of the state of New York. Any disputes relating to this DPA will be subject to the exclusive jurisdiction of the courts of the state of New York, United States of America.

1. Modification of this DPA

This DPA may only be modified by a written amendment signed by both Company and Customer.

1. Invalidity and severability

If any provision of this DPA is found by any court or administrative body of a competent jurisdiction to be invalid or unenforceable, then the invalidity or unenforceability of such provision does not affect any other provision of this DPA and all provisions not affected by such invalidity or unenforceability will remain in full force and effect.

ANNEX I

DESCRIPTION OF THE TRANSFER

1. LIST OF PARTIES

Data exporter:

• Name: Customer (as defined above)

• Address: See signature page above.

• Contact person’s name, position and contact details: See signature page above.

• Activities relevant to the data transferred under these Clauses: Customer receives Company’s services as described in the Agreement and Customer provides Personal Data to Company in that context.

• Signature and date: See signature page above.

• Role (controller/processor): Controller, or Processor on behalf of Third-Party Controller

Data importer:

• Name: Company (as defined above)

• Address: See signature page above.

• Contact person’s name, position and contact details: See signature page above.

• Activities relevant to the data transferred under these Clauses: Company provides its services to Customer as described in the Agreement and Processes Personal Data on behalf of Customer in that context.

• Signature and date: See signature page above

• Role (controller/processor): Processor on behalf of Customer, or Subprocessor on behalf of Third-Party Controller

• DESCRIPTION OF INTERNATIONAL DATA TRANSFER

• Categories of Data Subjects whose Personal Data is transferred:

• Categories of Personal Data transferred:

• 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.

• Junior does not knowingly collect (and Customer shall not knowingly submit) any special categories of data (as defined under the Data Protection Laws) and terms of this addendum and the Agreement do not permit Customers or Users to upload any such special categories of data.

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

• Nature of the processing:The Personal Data will be processed and transferred as regards to the use of large language models to format, condense and extract data points from the market research interview transcript.

• Purpose(s) of the data transfer and further processing:The Personal Data will be transferred and further processed for the provision of the Services to assist Customer in conducting market research interview programs.

• 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 for as long as necessary taking into account the purpose of the Processing, and in compliance with applicable laws, including laws on the statute of limitations and Data Protection Law.

• For transfers to (sub-) processors, also specify subject matter, nature and duration of the processing:For the subject matter and nature of the Processing, reference is made to the Agreement and this DPA. The Processing will take place for the duration of the Agreement.

• COMPETENT SUPERVISORY AUTHORITY

• The competent authority for the Processing of Personal Data relating to Data Subjects located in the EEA is the Office of the Data Protection Commissioner located at Canal House, Station Road, Portarlington, Co. Laois, R32 AP23, Ireland.

• The competent authority for the Processing of Personal Data relating to Data Subjects located in the UK is the UK Information Commissioner.

• The competent authority for the Processing of Personal Data relating to Data Subjects located in Switzerland is the Swiss Federal Data Protection and Information Commissioner.

ANNEX II

TECHNICAL AND ORGANIZATIONAL MEASURES INCLUDING TECHNICAL AND ORGANIZATIONAL MEASURES TO ENSURE THE SECURITY OF THE DATA

Description of the technical and organizational measures implemented by the data importer(s) (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.

Data Importer maintains and enforces industry standard technical and organizational measures to protect Personal Data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access and ensure a level of security appropriate to the risk of its processing of Personal Data processing consistent with its obligations under the Agreement and the GDPR. These measures shall include a comprehensive information security program that includes administrative, physical and technical safeguards for protection of the security, confidentiality and integrity of Personal Data that are appropriate to the type of information that Data Importer will process. Data Importer shall regularly monitor compliance with these safeguards.

To mitigate the risk to information processing resources, unauthorized disclosure or erasure of information and interruption of support for business processes which may result from unauthorized access, security controls implemented by the Data Importer are included in the following sections:

● Organizational Control – Measures which comply with the specific requests of Data Protection, regarding the internal organization such as commitment of employees to data secrecy, data backup/deletion, spatial/personal separation of data from other Clients etc.

● Entry Control – Measures to limit entrance of unauthorized persons to areas where Personal Data is used or processed such gate control, identification badges/code cards etc.

● Admission Control – Measures to limit admission of unauthorized persons to systems where Personal Data is used or processed such as safeguarding of physical network infrastructure, firewalls etc.

● Access Control – Measures to limit access of unauthorized persons to systems where Personal Data is used or processed such as having least privilege/selective access policy, use of encryption, audit logging, individual user ids/strong passwords, regulated procedures for granting, changing and revocation of access rights etc.

● Transmission Control – Measures to ensure that Personal Data cannot be read, copied, modified or removed without authorization such as use of encryption both at rest and in transit, audit logging to have retrospect information which data has be retrieved by whom etc.

● Availability Control – Measures to ensure that personal data is protected from accidental destruction or loss such as fail over capabilities, regular tested backups stored in multiple locations and disaster recovery plan, change management process etc.

● Separation Control – Measures to ensure that data collected for different purposes can be processed separately such use of separate user roles, logical/physical separation of data etc.

ANNEX III

LIST OF SUBPROCESSORS

Customer authorizes Company to engage the following Subprocessors: