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Data Transfer Addendum (DTA)

Last Updated: August 1, 2025

This Data Transfer Addendum ("Addendum") forms part of the Data Processing Addendum ("DPA") between the Customer and Blend Lab FZE ("Bunud"). This Addendum governs the cross-border transfers of personal data processed on behalf of the Customer as part of the Services provided by Bunud.

1. Purpose

This Addendum is intended to ensure that any international transfers of personal data by Bunud comply with applicable data protection laws, including but not limited to:

  • The Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data in the United Arab Emirates;

  • The EU General Data Protection Regulation (GDPR);

  • Other applicable cross-border data transfer regulations.

2. Scope

This Addendum applies where personal data is transferred:

  • From the UAE or another jurisdiction with data transfer restrictions;

  • To a country or territory that does not provide an adequate level of data protection as determined by the applicable authority;

  • As part of the provision of the Bunud Services.

3. Transfer Mechanisms

Bunud will only transfer personal data internationally using one or more of the following legally approved mechanisms:

  • Adequacy Decisions: Where the destination country has been recognized by a competent authority as providing adequate protection.

  • Standard Contractual Clauses (SCCs): Where applicable under EU or UK law, Bunud will use the latest approved SCCs as published by the European Commission or the UK Information Commissioner's Office.

  • Binding Corporate Rules (BCRs): Where applicable and approved, intra-group data transfers may rely on BCRs.

  • Supplementary Measures: Where required, Bunud will implement appropriate technical and organizational safeguards (e.g., encryption, pseudonymization, access controls) to ensure data subject protection.

4. Subprocessors and Hosting Locations

Bunud may use subprocessors and cloud infrastructure providers located outside the UAE or EU. All such subprocessors will be subject to the safeguards outlined in this Addendum, and a list of subprocessors with their locations is maintained at: www.bunud.ai/legal/subprocessors

5. Data Subject Rights and Assistance

Bunud will assist the Customer in fulfilling its obligations to respond to data subject requests related to cross-border transfers, including:

  • Informing individuals of international data transfers;

  • Responding to access, correction, or erasure requests involving data stored abroad.

6. Conflict and Precedence

In the event of a conflict between this Addendum and any other agreement, this Addendum shall prevail to the extent necessary to comply with data protection laws relating to cross-border transfers.

7. Contact

For any questions or to request a copy of the applicable transfer mechanism or contractual clauses, please contact:

Blend Lab FZE
Email: legal@bunud.ai
Website: www.bunud.ai/legal

This Addendum is deemed accepted by Customers using the Bunud Service, and forms part of the contractual obligations where data transfers apply.