JJ Internet Projects
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Terms

This document sets out the arrangements between you and Jay Jay Internet Projects B.V. when you use one of our websites or services. We apply different revenue models — sometimes we act as an intermediary between you and a third party, sometimes we provide a service to you directly. For that reason this document has a modular structure.

How to read this document. The General Part (articles 1 to 16) applies to all users of all our websites and services. The Specific Parts that follow apply only to the particular service you use. Where the General Part and a Specific Part differ, the Specific Part prevails.

Mode of address. By “you” we mean anyone who uses our websites or services, whether as a consumer or as a business. By “we”, “us” or “JJIP” we mean Jay Jay Internet Projects B.V.

Version 1.0 — adopted on 27 May 2026 — entered into force on 27 May 2026

Table of contents

Part I — General Part

  1. Who we are
  2. Definitions
  3. Applicability
  4. Our Platforms
  5. User representations
  6. Prohibited use
  7. Complaints about content posted by others (notice and takedown)
  8. Intellectual property of JJIP
  9. Content you provide (Contributions)
  10. Privacy
  11. Complaints and informal dispute resolution
  12. Liability
  13. Changes to these Terms
  14. Governing law
  15. Forum
  16. Other provisions

Part II — Specific Parts

  1. Module A — Intermediation for third-party offers
  2. Module B — Digital invitations and announcements
    1. B.1 Consumers
    2. B.2 Business Customers

Annexes

  1. Applicable Platforms
  2. Data Processing Agreement (Module B.2)

Part I — General Part

1. Who we are

Jay Jay Internet Projects B.V., trading as JJ Internet Projects, is a private limited company incorporated under Dutch law and established in Arnhem.

AddressPoggenbeekstraat 10, 6813 KG Arnhem, the Netherlands
Chamber of Commerce number24315808
VAT numberNL809799741B02
Central contactservice@jjip.nl

For each platform or website we use a dedicated customer contact address in the form service@[platformname]. An up-to-date overview is set out in Annex 1.

2. Definitions

In these General Terms and Conditions the following terms have the meaning set out below.

Account — a user account that you register on a Platform giving you access to certain Services.

Business Customer — a legal entity, or a natural person acting in the course of a business or profession, that enters into a B2B agreement with us under Module B.2.

Consumer — a natural person acting for purposes outside his or her trade, business or profession.

Contribution — all content that you post, upload, submit or otherwise make available on or through a Service, including text, images, video, audio, reviews, RSVPs and guestbook messages.

General Terms — this document, including all Annexes and Specific Parts.

Intermediation Platform — a JJIP website on which offers from Third-Party Providers are presented. Our Intermediation Platforms are listed in Annex 1.

Invitation Platform — a Platform on which JJIP itself provides the Service of creating, publishing and sharing digital invitations and announcements. Our Invitation Platforms are listed in Annex 1.

Platform — any JJIP website or online environment, including the websites listed in Annex 1.

Services — all services that JJIP provides to you through its Platforms, including Intermediation Services and Invitation Services.

Third-Party Provider — a publisher, training provider or other party whose offer is presented to you through an Intermediation Platform.

3. Applicability

These General Terms apply to every use of our Platforms and to every agreement that you enter into with us. By visiting our Platforms or using a Service, you confirm that you have read and accepted these Terms.

We expressly reject the applicability of any purchase conditions or other terms that you may seek to impose.

The General Part applies to every user. In addition, the Specific Parts apply where the Service described in those parts is relevant to your situation. Where the General Part and a Specific Part conflict, the Specific Part prevails. Where these Terms conflict with a separate written agreement between you and us, the separate agreement prevails.

4. Our Platforms

An overview of our current Platforms, their nature (Intermediation Platform or Invitation Platform), the applicable retention periods and the customer contact address is set out in Annex 1.

We reserve the right to add new Platforms, to change or discontinue existing Platforms, and to amend their content, layout and functionality. We are not obliged to keep Platforms available or to maintain any particular feature.

5. User representations

By using our Services you represent and warrant that:

  1. you are of legal age under the law of the country where you reside, or, if you are younger, that a parent or guardian has unequivocally consented and has accepted these Terms on your behalf;
  2. all information you provide to us is accurate, complete and up to date, and that you will update this information promptly when it changes;
  3. you act in your own name or on behalf of a legal entity or organisation that you lawfully represent;
  4. you do not use the Services for any purpose that contravenes the law or these Terms;
  5. you keep your login credentials confidential and that you are liable for all use that takes place under your Account, including by third parties, unless you can demonstrate that such use occurred through no fault of your own.

6. Prohibited use

You may not use our Platforms or Services to:

  1. post or distribute content that is unlawful, defamatory, insulting, threatening, harassing, discriminatory, sexually explicit involving minors, or otherwise offensive;
  2. infringe intellectual property rights, privacy or image rights, or trade secrets of third parties;
  3. distribute spam, chain letters, unsolicited commercial messages, or pyramid or similar schemes;
  4. impersonate another person, use false identities, or misrepresent the source of content;
  5. disrupt, circumvent or overload the operation, security or integrity of a Platform, including through viruses, malicious code, denial-of-service attacks, or excessive automated querying of our systems;
  6. use automated means (such as scrapers, bots or crawlers) to collect data from a Platform, other than through publicly available RSS feeds or APIs that we have expressly opened for that purpose;
  7. decompile, reverse-engineer or imitate the source code of a Platform, except to the extent permitted by mandatory law;
  8. harass, threaten or harm our staff, suppliers or other users;
  9. sell, rent or transfer an Account to a third party.

If you breach this article we may — in addition to any other measures — remove your Contribution, suspend or terminate your Account, and, where appropriate, file a criminal complaint or report the matter to the authorities. You will have no claim to a refund in such cases.

7. Complaints about content posted by others (notice and takedown)

If you consider that a Contribution by another user is unlawful, infringes rights, or otherwise contravenes these Terms, you may report this to us at service@jjip.nl or via the customer contact address of the relevant Platform.

A report must include at least:

  1. a precise identification of the disputed Contribution (URL or location);
  2. a description of the grounds on which the report is based;
  3. any evidence available to support your claim;
  4. your contact details.

We will assess each report as quickly as possible and at the latest within 14 days. If the report appears justified on its face, we may temporarily disable access to the disputed Contribution while we investigate. The person who posted the Contribution will be informed of the report and given seven days to respond, except in urgent cases.

We will then issue a reasoned decision, which we will communicate to both parties. There is no internal right of appeal against our decision; the parties may bring the dispute before the ordinary courts in accordance with article 15.

In the event of repeated infringements, we reserve the right to suspend or terminate the infringer’s Account.

8. Intellectual property of JJIP

All intellectual property rights in our Platforms, including but not limited to the source code, databases, design, templates, logos, trade names, illustrations, photographs, videos and editorial text, belong to JJIP or to its licensors. Nothing in these Terms transfers any right to you other than a personal, non-exclusive, revocable and non-transferable right to use the Services for the duration of your use.

You may not, without our prior written consent, reproduce, publish, store in an automated database, or exploit our content or trademarks for commercial or editorial purposes, except to the extent permitted by mandatory law.

9. Content you provide (Contributions)

You retain all rights in the Contributions that you post on a Platform. You are responsible for your own Contributions and warrant that you hold the rights and permissions required to post, share and — where applicable — allow others to use those Contributions in the context of the Service.

Limited licence to JJIP. You grant us, for the duration of your use of the Services, a limited, non-exclusive, royalty-free, worldwide licence to host, store, copy, display and, where required for the functionality of the Service, technically adapt your Contributions (such as creating thumbnails or transcoding for display), to the extent necessary to provide the Service to you and to the persons you have invited.

This licence is not used for advertising or marketing purposes outside the Service itself. The licence ends upon termination of your Account or upon removal of a Contribution, subject to a reasonable run-off period of no more than 30 days for back-up deletion.

Indemnity. You indemnify us against claims by third parties arising from Contributions that you have posted on a Platform in breach of these Terms or of third-party rights.

10. Privacy

For the processing of your personal data we refer you to our Privacy Policy, which is available on every Platform. The Privacy Policy forms part of these Terms. For the processing of cookies we refer you to our Cookie Policy.

When we provide services to Business Customers and process personal data on behalf of the Business Customer, the Data Processing Agreement included as Annex 2 to these Terms applies.

11. Complaints and informal dispute resolution

We value a good relationship with our users. If you have a complaint about a Service, we would like to hear it from you first, before you consider legal action.

You can submit your complaint at service@jjip.nl or via the customer contact address of the relevant Platform. We will respond substantively to your complaint within 14 business days. If we cannot give a final response within that period, you will receive an interim message setting out the reasons and an indication of when we will be able to respond substantively.

If we cannot resolve the matter together, Consumers in the European Union may submit a complaint to the European Commission’s Online Dispute Resolution platform at https://ec.europa.eu/odr. In addition, recourse to the ordinary courts is available in accordance with article 15.

12. Liability

General rule. Our liability to you under any agreement or on any other basis is limited to direct damages. We are not liable for indirect damages, consequential damages, loss of profit, loss of savings, damage caused by business interruption, loss or corruption of data, reputational damage or non-material damages, except to the extent that mandatory law provides otherwise.

Caps per type of Service. The extent of our liability is capped per type of Service as set out below.

  • For Intermediation Services (Module A): EUR 100 per event and EUR 500 per calendar year.
  • For Invitation Services to Consumers (Module B.1): the amount you have paid to us in the twelve months preceding the event causing the damage, with an absolute maximum of EUR 500.
  • For Invitation Services to Business Customers (Module B.2): the amount the Business Customer has paid to us in the twelve months preceding the event causing the damage, with an absolute maximum of EUR 2,500.

Exceptions. The exclusions and limitations set out above do not apply in the event of intent or wilful recklessness on our part, nor to the extent that such exclusion or limitation is not permitted under mandatory law, including consumer protection rules.

No liability for third parties. We are not liable for the acts or omissions of Third-Party Providers, of Business Customers towards their end users, or of other users of our Services. For complaints about the performance of an offer by a Third-Party Provider, we refer you to that Third-Party Provider.

Force majeure. We are not liable where a failure results from force majeure, including disruptions or outages of the internet, telecommunications or energy supplies, cyber-attacks, government measures, war, pandemic, or a failure by a supplier engaged by us.

13. Changes to these Terms

We reserve the right to amend these Terms.

For users of Intermediation Platforms (Module A). Changes will be published on the relevant Platform, stating the date on which they enter into force. By continuing to use the Platform after that date, you accept the amended Terms.

For users of Invitation Platforms (Module B). We will announce changes at least 30 days before they enter into force, by email to the address you have provided and through a notice on the Platform. If you do not agree with a change, you may terminate your Account free of charge before the entry-into-force date.

Exceptions to the notice period. Changes that are solely in your favour (such as a reduction in fees or an extension of rights), changes that result from a mandatory amendment of legislation or regulation, and corrections of obvious typographical errors or omissions may be implemented without prior notice.

14. Governing law

These Terms and all agreements between you and us are governed exclusively by Dutch law. The applicability of the Vienna Sales Convention (CISG) is expressly excluded.

If you are a Consumer with habitual residence in the European Union, the protection you enjoy under the mandatory rules of the law of your country of residence remains in full force.

15. Forum

Disputes with Consumers that cannot be resolved informally will be submitted to the competent court in the district where JJIP has its registered office, namely the District Court of Gelderland, location Arnhem. A Consumer with habitual residence in the European Union is also entitled to bring the dispute before the court of his or her place of residence.

Disputes with Business Customers will be submitted exclusively to the District Court of Gelderland, location Arnhem.

16. Other provisions

Severability. If any provision of these Terms proves wholly or partly void or voidable, the remaining provisions remain in full force. The void or voided provision will be replaced by a provision that approximates the intent of the original provision as closely as possible and that is legally valid.

No waiver. Failure to enforce, or delay in enforcing, a right under these Terms does not constitute a waiver of that right.

Assignment. We may assign our rights and obligations under these Terms, in whole or in part, to a third party, for example in the context of a reorganisation or acquisition. You may assign your rights and obligations only with our prior written consent.

Electronic communications. Communications between you and us may validly take place by email and through the Platforms. You consent to the electronic signature of agreements and to the electronic delivery of notices.

Language versions. These Terms are available in Dutch and English. Shorter landing-page versions may be available in other languages. In the event of any difference in interpretation between the Dutch version and a translation, the Dutch version is binding.

Part II — Specific Parts

Module A — Intermediation for third-party offers

A.0 Applicability

This Module A applies to your use of the Intermediation Platforms listed in Annex 1, which include in any event abonnement.nl, abonnement.be, proefabonnement.nl, vakbladen.nl and thuisstudie.nl.

A.1 Our role as intermediary

JJIP operates the Intermediation Platforms and presents on them offers from Third-Party Providers. We bring you and the Third-Party Provider together and arrange, depending on the Platform and the provider, either the transfer of your application or a direct redirection to the Third-Party Provider’s order environment.

JJIP is not a party to the eventual agreement between you and the Third-Party Provider. That agreement is concluded directly between you and the Third-Party Provider. JJIP does not collect subscription fees, tuition fees or any other amounts due for the underlying service of the Third-Party Provider.

JJIP receives a fee for its intermediation from the Third-Party Provider or from an affiliate network acting as intermediary. There are no costs to you for our intermediation.

A.2 Application and acceptance

When you submit an application on an Intermediation Platform, JJIP forwards that application to the relevant Third-Party Provider or redirects you to its order environment. Acceptance of your application, the drafting of the agreement, its performance, invoicing and collection rest exclusively with the Third-Party Provider.

JJIP does not guarantee that an application will be accepted by a Third-Party Provider. A Third-Party Provider may refuse or suspend an application on its own grounds without giving rise to any rights against JJIP.

A.3 Information, prices and offers

We strive to present offers on the Intermediation Platforms accurately and in an up-to-date manner. However, the offers, prices and conditions shown on an Intermediation Platform are indicative and may be changed by the Third-Party Provider at any time. The final terms of the agreement are set by the Third-Party Provider.

JJIP is not liable for inaccuracies, outdated information or incompleteness in the offers presented on the Intermediation Platforms, except in the event of intent or wilful recklessness on our part.

A.4 Complaints about the Third-Party Provider

Complaints about the content, delivery, invoicing, collection, cancellation or performance of the agreement with a Third-Party Provider must be submitted directly to that Third-Party Provider. JJIP has no influence over that agreement and is not liable for it.

We are happy to assist you with general information on how to file a complaint with a Third-Party Provider, but we do not act as your authorised representative or as a complaints officer on behalf of you or the Third-Party Provider.

A.5 Reviews and ratings

On an Intermediation Platform we may offer you the opportunity to post a review or rating of a Third-Party Provider or its offer. The provisions on Contributions in the General Part apply to the posting of a review. In addition, a review:

  1. is based on your own, recent and direct experience;
  2. contains no factual inaccuracies or misleading suggestions;
  3. contains no abusive language, personal attacks or discriminatory expressions;
  4. contains no confidential information or personal data of third parties;
  5. is not posted by, or on behalf of, a competitor in order to harm a Third-Party Provider.

We reserve the right to moderate, refuse or remove reviews if they conflict with this article or with the General Part.

A.6 Liability in intermediation

JJIP’s liability under this Module A is limited to direct damages that result directly from an attributable failure in our intermediation service, with a maximum of EUR 100 per event and EUR 500 per calendar year. The provisions of article 12 of the General Part apply in addition.

Module B — Digital invitations and announcements

B.0 Applicability

This Module B applies to your use of the Invitation Platforms listed in Annex 1, which include in any event eventinfo.pro and rouwkaarten.online. Module B is divided into a section for Consumers (B.1) and a section for Business Customers (B.2).

B.1 Consumers

B.1.1 Product definition. On an Invitation Platform you may, for a fee, have a digital invitation or announcement composed and published. The Service typically includes:

  1. an online editor to design your invitation based on a template;
  2. publication of an invitation page at a URL hosted by us;
  3. an email version of the invitation to send to invitees;
  4. social media images that you can download and share;
  5. optional features such as collecting RSVPs, a guestbook, calendar integration and route information.

The exact composition of the Service, the retention period of your invitation and the applicable fees vary per Invitation Platform. An overview is set out in Annex 1; current fees are shown during the ordering process on the relevant Platform.

B.1.2 Ordering process. The ordering process is as follows:

  1. you create an Account on the relevant Invitation Platform;
  2. you compose your invitation in the editor;
  3. you pay for the product of your choice using one of the offered payment methods (including iDeal, credit cards, PayPal, Apple Pay, Google Pay and, where applicable, Bancontact);
  4. after successful payment you may continue to adjust your invitation until you share or publish it;
  5. once you share or publish the invitation, we consider the Service for that invitation to be fully performed.

All amounts are in euros and, where required by law, inclusive of VAT. We reserve the right to correct obvious pricing errors, even after receipt of payment, and to settle or refund the difference accordingly.

B.1.3 Credit bundles and credits. We may offer credit bundles or credits on an Invitation Platform that allow you to purchase multiple invitations against an advance payment. The validity period of credits is stated on the Platform. Unused credits cannot be exchanged for cash, subject to the provisions on withdrawal in B.1.4.

B.1.4 Right of withdrawal. As a Consumer, you have the right under article 6:230o of the Dutch Civil Code to terminate the agreement, without giving reasons, within fourteen days of its conclusion.

Commencement of the Service and lapse of the right of withdrawal. By placing your order, you expressly request that we begin performing the Service immediately, and you acknowledge that your right of withdrawal lapses when the Service has been fully performed. For the Service under Module B.1, the Service is deemed to have been fully performed when you share or publish the invitation (see B.1.2 under e).

Until that moment you may withdraw your order free of charge and without giving reasons by notifying us via the customer contact address of the relevant Platform, or using the model form available on request. We will refund the amounts you have paid within fourteen days of withdrawal, using the same payment method that you used.

For credit bundles and credits, unused credits may be withdrawn within 14 days of purchase; credits already used may not.

B.1.5 Refunds outside the right of withdrawal and goodwill. Outside the right of withdrawal and outside an attributable failure on our part, you are not entitled to a refund. We assess requests for goodwill — for example where an event does not take place or where you have made a mistake — on a case-by-case basis. We respond to a goodwill request within five business days. Our decision is final.

B.1.6 Access by entitled persons. We recognise that situations may arise around an invitation service — in particular in relation to memorial card services — in which the original holder of an Account is no longer able to manage it. At the request of an entitled person, for example an executor or a first-degree family member, we may, in such cases, arrange a one-time access or transfer. We assess each request on its own merits, ask for reasonable evidence of the requester’s status, and are not obliged to honour any request. We accept no liability if we are unable to grant access, or unable to grant access in time.

B.1.7 Retention and deletion. A published invitation remains available for the retention period stated in Annex 1, calculated from the date of publication. After that period we automatically delete the invitation.

If you terminate your Account before the end of the retention period, we delete the associated content within a reasonable period, with a run-off of no more than 30 days for removal from regular back-ups.

B.1.8 Liability Module B.1. In addition to article 12 of the General Part, our liability to a Consumer under Module B.1 is limited to the amount the Consumer has paid to us in the twelve months preceding the event causing the damage, with an absolute maximum of EUR 500.

B.2 Business Customers

B.2.1 Applicability and target audience. Module B.2 applies to Business Customers entering into a business subscription agreement with JJIP for the use of an Invitation Platform. Our business services are aimed at business customers in a broad sense, including event agencies, funeral services, hospitality providers, HR departments, municipalities, associations and foundations.

B.2.2 The business service. The business service consists of a combination of:

  1. Access and subscription. Access to the Invitation Platform under an ongoing subscription, with the features described in this article.
  2. Own domain. The ability to publish invitations under a subdomain or own domain designated by the Business Customer.
  3. Own branding. The ability to apply the Business Customer’s branding (logo, colour scheme, typographic preferences) within the Platform and in the published invitations.
  4. White-label. The ability to hide JJIP’s brands and branding largely or entirely, so that the Business Customer can present the Platform under its own brand to its own customers or relations.

The precise scope, limitations and parameters of these features will be recorded between you and us in writing or by electronic means, for example in an order confirmation.

B.2.3 Fees. The fee for the business service consists of:

  1. a fixed monthly subscription fee, and
  2. a variable fee based on credits per event or per generated invitation.

The current rates are agreed when the contract is concluded and may be changed during the term in accordance with article 13 of the General Part. Unless otherwise agreed, fees are invoiced annually in monthly instalments or prepaid periods, and all amounts are exclusive of VAT.

B.2.4 Term and termination. Unless otherwise agreed in writing, the subscription is entered into for an indefinite period and may be terminated monthly with effect from the end of the current calendar month. Any annual subscription is automatically renewed after the initial term for a further twelve months, with the proviso that during the renewed period a notice period of one calendar month applies.

Termination takes place through the account settings of the Platform or by email to the customer contact address of the relevant Platform.

In the event of interim termination, no refund will be made of subscription fees already invoiced or prepaid for the current month. Unused prepaid credits will be refunded on a pro rata basis.

B.2.5 End users and sublicensing. The Business Customer may use the Invitation Platform to enable its own customers, relations and invitees to receive, view, respond to and — where the Business Customer offers this — configure invitations within templates set up by the Business Customer.

The Business Customer is not permitted to resell the Platform or its functionality to third parties in such a way that those third parties go on to operate the Platform under their own brand or to offer it as a standalone service to their own customers outside the scope of the agreement between the Business Customer and JJIP.

The Business Customer warrants to JJIP that its end users comply with this General Part, in particular with article 5 (Representations) and article 6 (Prohibited use). A breach by an end user is treated as a breach by the Business Customer towards JJIP.

B.2.6 Processing of personal data. To the extent that we process personal data on behalf of the Business Customer in the performance of the agreement (for example personal data of its end users, invitees or employees), the Data Processing Agreement attached as Annex 2 to these General Terms applies. The Business Customer is then the controller and JJIP is the processor.

B.2.7 Data export on termination. After termination of the subscription, the Business Customer has 60 days to export the data present in its environment, including guest lists in a commonly used data format and the invitations generated by or through the Platform. After this period we delete the data in accordance with our regular retention policy.

B.2.8 Liability Module B.2. In addition to article 12 of the General Part, our liability to a Business Customer under Module B.2 is limited to the amount the Business Customer has paid to us in the twelve months preceding the event causing the damage, with an absolute maximum of EUR 2,500. Liability for indirect damages, consequential damages, loss of profit and loss of savings is fully excluded as against a Business Customer, except in the event of intent or wilful recklessness on our part.

Annex 1 — Applicable Platforms

The overview below shows the current Platforms of JJIP. We reserve the right to supplement or amend this overview.

Platform Type Customer contact Publication retention
abonnement.nlIntermediation Platformservice@abonnement.nln/a
abonnement.beIntermediation Platformservice@abonnement.ben/a
proefabonnement.nlIntermediation Platformservice@proefabonnement.nln/a
vakbladen.nlIntermediation Platformservice@vakbladen.nln/a
thuisstudie.nlIntermediation Platformservice@thuisstudie.nln/a
eventinfo.proInvitation Platform (B2C and B2B)service@eventinfo.pro12 months after publication
rouwkaarten.onlineInvitation Platform (B2C)service@rouwkaarten.online24 months after publication

Current rates for the Invitation Platforms are shown on the relevant Platform.

Annex 2 — Data Processing Agreement (Module B.2)

This Data Processing Agreement applies to Business Customers under Module B.2 where JJIP processes personal data on behalf of a Business Customer.

1. Parties and capacities

In this Data Processing Agreement, the Business Customer acts as controller (“Controller”) and JJIP acts as processor (“Processor”) within the meaning of the General Data Protection Regulation (GDPR).

2. Subject, nature and purpose of the processing

The Processor processes personal data solely for the services described in the main agreement, namely hosting, presenting and operating an Invitation Platform for the Controller and its end users.

3. Types of personal data and categories of data subjects

The processing concerns at least: name and address details, email addresses, telephone numbers (where provided), RSVP status, guestbook contributions and any images and texts uploaded by the Controller or its end users. The data subjects are: employees of the Controller, customers and relations of the Controller, and invitees to the events published through the Platform.

4. Instructions

The Processor processes personal data solely on the basis of written instructions from the Controller, except where required otherwise by law. The main agreement and these General Terms serve as documentation of those instructions.

5. Confidentiality

The Processor ensures that persons processing personal data under its authority are bound by a duty of confidentiality based on a statutory or contractual obligation.

6. Security

The Processor takes appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including, where appropriate: encryption of transport and storage, access restriction on a need-to-know basis, periodic back-ups, logging of changes, and recovery measures in the event of incidents.

7. Sub-processors

The Processor may engage sub-processors to perform its work. A current overview of structural sub-processors is provided to the Controller on request. When a sub-processor is replaced or added, the Processor notifies the Controller with reasonable advance notice, so that the Controller can raise a reasoned objection.

8. Rights of data subjects

The Processor provides the Controller with reasonable assistance in responding to requests from data subjects exercising their rights under the GDPR (access, rectification, erasure, restriction, data portability and objection). Requests from data subjects addressed directly to the Processor are forwarded to the Controller as quickly as possible and in any event within ten business days.

9. Personal data breaches

The Processor informs the Controller without undue delay — and in any event within 48 hours of becoming aware of it — of a personal data breach within the scope of this Data Processing Agreement, setting out the nature of the incident, the data affected, the data subjects affected or potentially affected, and the measures taken or planned.

10. Transfer outside the EEA

Transfer of personal data to countries outside the European Economic Area takes place only to the extent that an appropriate level of protection is ensured, for example on the basis of an adequacy decision or a model contract adopted by the European Commission.

11. Audits

The Controller may, once per calendar year, have an audit carried out by an independent expert to verify compliance with this Data Processing Agreement, on reasonable notice, at the Controller’s expense, and in a manner that disrupts the Processor’s operations as little as possible.

12. Termination

On termination of the main agreement, the personal data will, at the Controller’s request, be returned in a commonly used data format or deleted, subject to any statutory retention obligation.

13. Liability

Without prejudice to article 12 and article B.2.8 of these General Terms, the parties indemnify each other against fines and claims from data subjects to the extent that these result from an attributable failure of the other party in the performance of this Data Processing Agreement.

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