DATA PROCESSING ADDENDUM

Last updated: October 1, 2026

This Data Processing Addendum (“DPA”) applies when Phoenix Moirai LLC processes personal information on behalf of a customer in connection with the hosting Services.

This DPA supplements the Phoenix Moirai LLC Website Hosting Terms of Service and Privacy Policy.

1. Roles of the Parties

For personal information that a customer places on Phoenix Moirai LLC’s hosting infrastructure:

• The customer generally acts as the party determining the purposes and means of processing; and
• Phoenix Moirai LLC generally acts as a service provider, processor, or similar role to the extent defined by applicable privacy law.

The parties will comply with applicable privacy laws governing their respective obligations.

2. Customer Responsibilities

The customer is responsible for:

• Determining the lawful basis for processing personal information;
• Providing required privacy notices to its users;
• Obtaining required consents;
• Responding to requests from its users where required;
• Configuring its website and applications appropriately; and
• Ensuring that its use of the Services complies with applicable law.

3. Phoenix Moirai LLC Processing

Phoenix Moirai LLC may process personal information only as reasonably necessary to:

• Provide the hosting Services;
• Maintain and secure the infrastructure;
• Perform backups;
• Provide technical support;
• Prevent fraud and abuse;
• Troubleshoot technical issues;
• Comply with legal obligations; and
• Carry out documented instructions from the customer where applicable.

4. Confidentiality

Phoenix Moirai LLC will require personnel with access to customer information to maintain appropriate confidentiality obligations, subject to applicable law.

5. Security

Phoenix Moirai LLC will maintain reasonable administrative, technical, and physical safeguards appropriate to the nature of the Services.

No security measure can guarantee complete protection against unauthorized access.

6. Subprocessors

Phoenix Moirai LLC may use third-party service providers to provide infrastructure, backup, security, payment, networking, support, or other services.

Where required by applicable law, Phoenix Moirai LLC will maintain appropriate contractual and operational controls concerning subprocessors.

Subprocessor information:

• Siteground (SG Hosting, Inc.)

7. Data Breach

If Phoenix Moirai LLC becomes aware of a security incident affecting personal information processed on behalf of a customer, Phoenix Moirai LLC will take reasonable steps to investigate and mitigate the incident.

Where required by applicable law, Phoenix Moirai LLC will notify the customer within a reasonable period after confirming an incident requiring notification.

The customer remains responsible for determining whether notification to its own users, regulators, or other parties is legally required, unless applicable law provides otherwise.

8. Data Requests

Where reasonably possible, Phoenix Moirai LLC will provide reasonable assistance to customers responding to legally required requests concerning personal information hosted through the Services.

Requests that require substantial technical work may be subject to Phoenix Moirai LLC’s standard paid support rate.

9. Data Deletion

Upon termination of the Services, Phoenix Moirai LLC may delete Customer Content in accordance with the Terms of Service and applicable backup-retention practices.

The customer is responsible for exporting necessary information before termination.

10. International Transfers

If Customer Content is processed outside the customer’s jurisdiction, the parties will use applicable legal mechanisms required for such transfers where applicable.

11. Term

This DPA remains in effect for as long as Phoenix Moirai LLC processes personal information on behalf of the customer in connection with the Services.

12. Conflict

If this DPA conflicts with the Terms of Service concerning the processing of personal information, this DPA controls only to the extent of that conflict.

All other provisions of the Terms of Service remain in effect.