EX-10.38

Exhibit 10.38

MASTER DATA LICENSE AGREEMENT

INFORMATION PAGE



Client Legal Entity Name: Client D/B/A: (Does Business As):		Effective Date:

Client Address:		Telephone Number:

City: State/Provence: Country: Zip:		Fax Number:

Client Authorized Representative Name		Email Address: Phone Number:

Client Billing/Finance Contact Name:		Email Address: Phone Number:

Mobilewalla, Inc., (“Mobilewalla”), and the above named Client (“Client”) agree that all Licensed Data (defined below) obtained from Mobilewalla by Client shall only be furnished pursuant to the terms and conditions of this Master Data License Agreement (“Agreement”) attached hereto effective as of the date listed above (the “Effective Date”).

Each party agrees that it has read and understands this Agreement and each party agrees to be bound by all of its terms. The parties further agree that this Agreement, including its Exhibit(s), constitute the complete and exclusive understanding and agreement between them, and shall supersede and prevail over any prior proposals, terms in any purchase orders or other communications between them, oral or written, relating to the subject matter hereof, or any subsequent purchase orders or other standardized business forms. This Agreement may be executed in one or more counterparts, each of which will be deemed an original but all of which together will constitute one and the same instrument. Counterparts may be delivered via facsimile, electronic mail (including PDF), or other transmission method and any counterpart so delivered shall be deemed to have been duly and validly delivered and be valid and effective for all purposes.


MOBILEWALLA, INC.						Client Entity Name:

By:						By:
Authorized Signature						Authorized Signature

Jay D. Clark
Name (Please Print or Type)						Name (Please Print or Type)

COO
Title						Title

Address:

2472 Jett Ferry Road

Ste 400-214

Dunwoody, GA 30338

MASTER DATA LICENSE AGREEMENT

1. Client Responsibilities. Client is responsible for working with Mobilewalla to define the requirements for the Statement of Work in the form attached hereto as Exhibit A (“Statement of Work” or “SOW”) detailing the configuration of Licensed Data for Client’s Permitted Uses (defined below). Each Statement of Work shall be effective only upon execution by both parties. If Mobilewalla provides Client with credentials to access Licensed Data stored in Mobilewalla’s S-3 bucket (“S-3 Bucket”), the S-3 Bucket may only be accessed and used by those employees of Client who have been designated and authorized by Client to be granted such access (“Authorized Users”) for the sole purpose of performing their job functions for Client, and only up to the number of Authorized Users specified in the applicable Statement of Work. The credentials for each Authorized User are for a single individual only, they must be kept confidential, cannot be shared or used by more than one person. Client is responsible for all actions taken under an Authorized User’s credentials, whether or not such action was taken or authorized by the Authorized User.

2. Grant of License. Subject to Client’s compliance with the terms and conditions of this Agreement (including, without limitation, payment of the applicable fees in accordance with the applicable Statement of Work), Mobilewalla hereby grants to Client, and Client hereby accepts a limited, non-exclusive, non-transferable and non-assignable right and license to use the data provided by Mobilewalla to Client pursuant to the applicable Statement of Work (“Licensed Data”) for the purposes of (i) Client targeting content and advertisements to users’ web browsers, applications and mobile devices, and (ii) Client’s analytics and measurement purposes (“Permitted Uses”). Any other uses of Licensed Data are expressly prohibited without the prior, express written permission of Mobilewalla.

3. License Fees. Client shall pay to Mobilewalla the license fee (“License Fee”) set forth in the applicable Statement of Work in accordance with the schedule set forth therein. Such License Fees are exclusive of all sales, excise, use, or other taxes or fees imposed by any governmental authority in connection with the license or use by Client of the Licensed Data. The License Fee shall increase by 8% annually.

4. Payment. The License Fee shall be prepaid on an annual basis and payable under the applicable Statement of Work. Mobilewalla shall invoice Client and Client agrees to pay no later than thirty (30) days after the date of each such invoice. All invoices and payments will be in United States Dollars. Invoices shall be sent via email to the billing/finance contact address set forth on Information Page of this Agreement. Client agrees to make payments via electronic payment remittance (by wire or ACH). Any amount due hereunder not timely paid shall bear interest at the rate of 1.5% per month or portion thereof (or such lesser amount as may be the maximum permitted by law) that such payment remains outstanding after the due date. Mobilewalla may suspend performance upon failure by Client to timely pay any amount due hereunder. Client shall pay any attorneys’ fees and/or court costs incurred by Mobilewalla in collecting any payment due hereunder.

5. Term. This Agreement shall commence as of the Effective Date and shall remain in effect for a period of one (1) year thereafter (“Initial Term”). This Agreement shall automatically renew for like successive one (1) year terms (“Renewal Terms”) upon the expiration of the Initial Term or any Renewal Term unless either party gives notice of its desire not to renew this Agreement a minimum of ninety (90) days prior to any such scheduled expiration.

6. Termination. This Agreement may be terminated: (i) by either party upon breach by the other party of any term or provision contained herein and failure to cure same within sixty (60) days after receipt of notice from the non-breaching party describing such breach; (ii) by either party immediately upon the insolvency, (voluntary or involuntary) filing for bankruptcy, receivership, or assignment for the benefit of creditors of the other Party; (iii) by Mobilewalla upon fourteen (14) days advance notice upon Client’s failure to make timely payments hereunder. Termination of any applicable Statements of Work shall be dictated by the terms and conditions of each specific SOW unless otherwise stated herein.

Notwithstanding the foregoing, the term of this Agreement shall continue until all Campaigns and Initiatives in which the Licensed Data is used for the Permitted Use have been terminated or have expired, but in no event later than sixty (60) days after the end of the Initial Term or applicable Renewal Term to which the notice of termination relates. “Campaign” means the placement of advertisements on Client’s or third-party distribution networks for an advertiser through Client’s advertising services pursuant to a contract between the advertiser and Client.

Upon the effective date of termination or expiration of this Agreement: (i) Mobilewalla shall cease to provide the Licensed Data to Client; (ii) Client shall cease using and delete the Licensed Data in all forms and types of media within sixty (60) days, and provide Mobilewalla with an officer’s written certification, certifying to Client’s compliance with the foregoing; and (iii) Client shall pay all License Fees and amounts that accrued prior to such termination or expiration and thereafter (as applicable). Sections 3, 4, 6, 7 and 8 through 15 shall survive termination or expiration of this Agreement or any individual license granted hereunder. Upon a termination of this Agreement by Client under clause (i) or (ii) above, Mobilewalla shall return to Client any unearned portion of the fees paid in advance under any Statement of Work, calculated on a daily basis.

7. Ownership. Client expressly acknowledges that, as between Mobilewalla and Client, Mobilewalla owns all worldwide right, title and interest in and to the Licensed Data. Client acknowledges and agrees that it obtains no right of ownership in the Licensed Data by virtue of this Agreement and that the Licensed Data comprises: (i) works of original authorship of Mobilewalla, including compiled information containing Mobilewalla’s selection, arrangement and coordination and expression of information or pre-existing material it has created, gathered or assembled; and (ii) information that has been created, developed and maintained by Mobilewalla at substantial expense of time and money such that misappropriation or unauthorized use by others for commercial gain would unfairly and irreparably harm Mobilewalla. Client shall not commit or permit any act or omission that would impair Mobilewalla’s rights in the Licensed Data.

8. Restrictions on Use. Except as expressly permitted herein as a Permitted Use, no express or implied license is granted to Client to receive, reproduce, copy, market, sell, convey, distribute, license, sublicense, assign, lease, timeshare, modify, amend, publish, rent or otherwise use the Licensed Data. Client acknowledges and agrees that Licensed Data is data that is linked or intended to be linked solely to a particular browser or device and not to an identified natural person. Client agrees that it shall not: (i) receive, reproduce, copy, market, sell, convey, distribute, license, sublicense, assign, lease, timeshare, modify, amend, publish, rent or otherwise use the Licensed Data for any reason other than a Permitted Use; (ii) create derivative works, including without limitation, transactions, adaptions, arrangements or any other alteration, of the Licensed Data for any reason other than a Permitted Use; (iii) combine, merge, or append Licensed Data with any information that is linked or intended to be linked to a directly identified natural person (e.g., name, email address, phone number, address, etc.) (iv) allow any third parties to access the Licensed Data through any means; (v) incorporate the Licensed Data with or into any other data, application, product or service that discloses the Licensed Data to third parties or creates a competitive product or service with Mobilewalla; (vi) use Licensed Data to determine eligibility for employment, credit, healthcare, insurance, tenancy, or education admissions; or (vii) use Licensed Data to discriminate against, harass, or otherwise harm any person or third party. Client’s rights in the Licensed Data will be limited to those expressly granted in this Agreement; or (vii) use Licensed Data in law enforcement or governmental intelligence use cases. Mobilewalla reserves all rights and licenses in and to the Licensed Data not expressly granted to Client under this Agreement. If Licensed Data has an opt-out flag connected to it, Mobilewalla agrees that it will not pass or make available to Client such Licensed Data. Mobilewalla shall make available to Client any consumer consent requests and Client agrees to honor these requests in their own processing.

9. Mutual Warranties and Disclaimers. Each party represents and warrants to the other party that: (i) it has the full power and authority to enter into this Agreement; (ii) the execution of this Agreement and performance of its obligations under this Agreement do not and will not violate any other agreement to which it is a party; (iii) this Agreement constitutes a legal, valid and binding obligation of it when executed and delivered; and (iv) any and all activities it undertakes in connection with this Agreement will be performed in compliance in all material respects with applicable laws, rules and regulations.

THE LICENSED DATA IS PROVIDED “AS-IS.” EXCEPT AS EXPRESSLY SET FORTH IN THIS AGREEMENT, MOBILEWALLA DISCLAIMS ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NONINFRINGEMENT, AND ANY WARRANTIES ARISING OUT OF COURSE OF DEALING, USAGE OF TRADE. NO ADVICE OR INFORMATION, WHETHER ORAL OR WRITTEN, OBTAINED FROM MOBILEWALLA OR ELSEWHERE WILL CREATE ANY WARRANTY NOT EXPRESSLY STATED IN THIS AGREEMENT.

10. Limitation of Liability. EXCEPT FOR THE PARTIES’ OBLIGATIONS UNDER SECTION 11 (INDEMNIFICATION) AND SECTION 12 (CONFIDENTIAL INFORMATION) OF THIS AGREEMENT, IN NO EVENT WILL EITHER PARTY BE LIABLE TO THE OTHER PARTY FOR ANY INDIRECT, INCIDENTAL, PUNITIVE, SPECIAL, RELIANCE OR CONSEQUENTIAL DAMAGES OF ANY KIND OR NATURE WHATSOEVER, HOWEVER CAUSED, AND WHETHER BASED ON BREACH OF CONTRACT, TORT (INCLUDING WITHOUT LIMITATION GROSS NEGLIGENCE), OR ANY THEORY OF LIABILITY, SUFFERED BY THE OTHER PARTY, INCLUDING, WITHOUT LIMITATION, LOST PROFITS, BUSINESS INTERRUPTIONS OR OTHER ECONOMIC LOSS UNDER OR ARISING OUT OF THE PERFORMANCE OR NON-PERFORMANCE HEREUNDER, AND WHETHER OR NOT THE APPLICABLE PARTY WAS ADVISED OF THE POSSIBILITY OF SUCH LOSS OR DAMAGES. EXCEPT FOR THE PARTIES’ OBLIGATIONS UNDER SECTION 11 (INDEMNIFICATION) AND SECTION 12 (CONFIDENTIAL INFORMATION) OF THIS AGREEMENT, IN NO EVENT SHALL EITHER PARTY’S LIABILITY UNDER OR ARISING OUT OF THIS AGREEMENT EXCEED THE AMOUNTS PAID BY CLIENT TO MOBILEWALLA IN THE THREE (3) MONTH PERIOD PRECEDING THE INCIDENT GIVING RISE TO LIABILITY. NOTWITHSTANDING ANYTHING TO THE CONTRARY, UNDER NO CIRCUMSTANCES WILL EITHER PARTY’S TOTAL LIABILITY UNDER THIS AGREEMENT ARISING OUT OF OR IN CONNECTION WITH SECTION 11.2 (INDEMNIFICATION) EXCEED, IN THE AGGREGATE, THE TOTAL FEES PAID BY CLIENT TO MOBILEWALLA IN THE TWELVE (12) MONTH PERIOD PRECEDING THE INCIDENT GIVING RISE TO LIABILITY. THE PARTIES HAVE AGREED THAT THESE LIMITATIONS WILL SURVIVE AND APPLY EVEN IF ANY LIMITED REMEDY SPECIFIED IN THIS AGREEMENT IS FOUND TO HAVE FAILED OF ITS ESSENTIAL PURPOSE.

11. Indemnification.

11.1.

Each party agrees to indemnify and hold the other party harmless against any and all third party claims, actions or allegations resulting from such party’s breach of any of its representations made under Section 9 (Mutual Warranties; Disclaimers) or from its breach of Section 12 (Confidential Information) of this Agreement.

11.2.

Mobilewalla agrees to indemnify and hold Client harmless from and against any action brought by a third party to the extent that it is based upon a claim that the Licensed Data infringe any intellectual property rights of any third party.

12. Confidential Information. “Confidential Information” means: (i) the Licensed Data; (ii) business or technical information of Mobilewalla or Client that, if disclosed in writing, is marked “confidential” or “proprietary” at the time of disclosure, or, if disclosed orally, is identified as “confidential” or “proprietary” at the time of disclosure, and is summarized in a writing sent by the disclosing party to the other party within thirty (30) days of such disclosure; and (iii) the specific terms and pricing set forth in this Agreement.

Confidential Information does not include information that: (a) is or becomes generally known to the public through no fault of or breach of this Agreement by the receiving party; (b) is rightfully known by the receiving party at the time of disclosure without an obligation of confidentiality; (c) is independently developed by the receiving party without use of the disclosing party’s Confidential Information; or (d) the receiving party rightfully obtains from a third party without restriction on use or disclosure.

Each party will not use the other party’s Confidential Information except as necessary for the performance of its obligations or exercise of its rights under this Agreement and will not disclose such Confidential Information to any third party except to those of its employees and subcontractors that need to know such Confidential Information for the purpose of performing this Agreement, provided that each such employee and subcontractor is subject to a written agreement that includes binding use and disclosure restrictions that are at least as protective as those set forth herein. Each party will use all reasonable efforts to maintain the confidentiality of all such Confidential Information in its possession or control, but in no event less than the efforts that such party ordinarily uses with respect to its own proprietary information of similar nature and importance. The foregoing obligations will not restrict either party from disclosing Confidential Information of the other party: (w) pursuant to the order or requirement of a court, administrative agency, or other governmental body, provided that the party required to make such a disclosure gives reasonable notice to the other party to contest such order or requirement; and (x) on a confidential basis to its legal or financial advisors. In addition, each party may disclose the terms and conditions of this Agreement: (y) as required under applicable securities regulations; and (z) on a confidential basis to present or future providers of venture capital and/or potential private investors in or acquirers of such party.

To the extent any Confidential Information of a party rises to the level of a trade secret under applicable law, this Section 12 shall be applicable during the term of this Agreement and at all times thereafter (or the maximum duration otherwise authorized under such applicable law) so long as such Confidential Information remains a trade secret. To the extent any such Confidential Information of the disclosing party does not rise to the level of a trade secret under applicable law, this Section 12 shall be applicable during the term of this Agreement and thereafter for the greater of five (5) years or, if longer, for so long as such Confidential Information remains confidential.

13. Notices. All notices required or permitted hereunder shall be in writing and shall be deemed to have been duly given, made and received (i) when personally delivered, (ii) one (1) business day following the day when deposited with a commercially respected overnight delivery service such as Federal Express, or (iii) three (3) business days following the day when deposited with the United States Postal Service, when addressed to the address set forth on the Information Page to this Agreement.

14. Legal Jurisdiction. This Agreement shall be governed and construed in accordance with the laws of the State of Georgia, United States of America, excluding that body of law known as conflict of laws. Any legal action or proceeding arising under this Agreement will be brought exclusively in the federal or state courts located in the Northern District of Georgia and the parties hereby irrevocably consent to the personal jurisdiction and venue therein.

15. Miscellaneous. Any failure by a party at any time or from time to time to enforce and/or require strict compliance with any term or condition of this Agreement will not constitute a waiver of such term or condition. No waiver will be enforceable unless embodied in a writing signed by the party charged with such waiver. Except as expressly set forth in this Agreement, the exercise by either party of any of its remedies under this Agreement will be without prejudice to its other remedies under this Agreement or otherwise. Neither party will be responsible for any failure or delay in its performance under this Agreement (except for any payment obligations) due to causes beyond its reasonable control, including, but not limited to, labor disputes, strikes, lockouts, shortages of or inability to obtain labor, energy, raw materials or supplies, war, terrorism, riot, pandemics (including COVID-19), acts of God or governmental action. The parties to this Agreement are independent contractors and this Agreement will not establish any relationship of partnership, joint venture, employment, franchise, or agency between the parties. Neither party will have the power to bind the other or incur obligations on the other’s behalf without the other’s prior written consent. This Agreement may not be modified except by a written instrument which is signed by both parties. In the event of the invalidity, in whole or in part, of any term of this Agreement, the parties agree that such invalidity shall not affect the validity of any other term of this Agreement and that such term shall be subject to partial enforcement to the extent permitted under applicable law. Client will have no right to assign this Agreement, in whole or in part, by operation of law or otherwise, without Mobilewalla’s express prior written consent. Any attempt by Client to assign this Agreement, without such consent, will be null and of no effect. Mobilewalla may freely assign this Agreement. Subject to the foregoing, this Agreement shall inure to the benefit of and be binding upon the parties, their successors and assigns. In the event of a conflict between this Agreement and any Statement of Work, the Statement of Work shall control.

EXHIBIT A

Statement of Work #: 001

This Statement of Work (“SOW”) is effective as of _____________, 202_ and is governed by and incorporated into the terms and conditions of the Master Data License Agreement, dated as of _____________, 202_ (the “Agreement”) entered into between Mobilewalla and Client. Capitalized terms not defined in this SOW will have the meaning given to them in this Agreement.

Offer Good Until Date: The terms of this SOW are valid until xx/xx/xxx. If the parties have not agreed and completed the contracting process by the Offer Good Until Date, then the terms of this SOW shall be null and void.

Term. This SOW shall be for a term of one (1) year (Initial Period). The first year shall be the Initial Period and subsequent years shall be the Renewal Period(s). This SOW shall automatically renew for one-year terms after the Initial Period unless one of the Parties notifies the other party no later than forty-five (45) days from the expiry of the current term.

Termination. This SOW once executed shall be non-cancelable for convenience, however either Party may terminate this SOW in any Period for breach of this SOW or the Agreement that remains uncured for sixty (60) days. Upon Termination, both parties shall abide by all the terms of the SOW and the Agreement that survive the Termination and Client shall be entitled to and Mobilewalla shall return a proration of the License Fee that Client has prepaid for any portion of a Period that service will not be provided.

License Fee Payment Terms. Prior to the initial delivery of Licensed Data, Mobilewalla will invoice Client for the total fees payable under this SOW for the Period. (For example: for the three-year SOW, Mobilewalla will invoice Client the fee for the entire year). Invoices are due and payable prior to delivery. Annually, the License Fee shall be increased 8%.

Price and Term Summary:


Start Date:		mm/dd/year
End Date:		mm/dd/year
#Months:		xx


Total Data License Fees		$
Total History Data Fees		$

Total Price


Proof of Concept (POC) Phase Action Plan	Date	Owner-MW	Owner-Client	Completion Date
1) POC Duration: Start date and End date
2) Agreement on Use Cases a. b.	Xx/xx/xxxx
3) Agreement of Outcomes/Evaluation Criteria (success) a. b. c.	Xx/xx/xxxx
4) Data schema finalized	Xx/xx/xxxx
5) Data delivery mechanism finalized	Xx/xx/xxxx
6) Client delivers data to Mobilewalla (e.g. for matching)	Xx/xx/xxxx
7) Client evaluation (x days starting on date data delivered to client)	Xx/xx/xxxx
8) Meetings to review progress/findings/questions (15 to 30 min) a. Week 1 date b. Week 2 date c. Week 3 date	Xx/xx/xxxx
9) Go/no go decision – meeting date	Xx/xx/xxxx
10) Next steps agreed


Subscription Phase Items	GEOs	Delivery Frequency (daily, weekly, monthly, other)	Pricing	Comments
1) 2) 3) 4) 5)

History Data Pricing Details. Nearly all Mobilewalla clients purchase history data to “seed” their data processes. Mobilewalla highly encourages this and provides a discount for each month of history data purchased. The discount is offered per the Rate Card monthly fee. For example, if Client wants 3 months of history data for the United Kingdom, the price would be $17,500 * 60% or $10,500 for each month of history data.


History Data Purchase – Prior Months
Months of History Data		Discount From Rate Card
1 month history		25% per month of history
2 months history		30% per month
>3 months & <6 months history		40% per month
>6 months & <= 12 months of history		50% per month

1.	Licensed Data Configuration:


Data Description	GEOs	Frequency (Daily, Weekly, Monthly)
Example: Refresh Existing Device MAIDs with Location and provide new Device MAIDs with Location data. Lookback period is weekly		Weekly Refresh
(Please List all data elements per data schema definitions) • MAID/IFA • Date/Time • * Fill rates will be 100% for MAID/IFA and Time/Date stamp. Fill rates for other data elements will vary.

2.	Licensed Data Format and Delivery Options:

Data Delivery Options (Please Select):

•

API - JSON

•

Cloud Storage hosted by Mobilewalla

•

1.1 : AWS S3 Bucket (Valid only if client is also using AWS)

•

1.2 : Azure Blob Container

•

Cloud Storage hosted by Client

•

2.1 : AWS S3 Bucket

•

2.2 : Azure Blob Container

•

2.3 : Google Cloud Storage

Custom/Other – please explain: _________________________________________________

Data Delivery—Access Limitations Disclosure:

•

Cloud Storage hosted by Mobilewalla

•

Access to AWS S3 bucket is via AWS IAM role only, provided by Mobilewalla.

•

Access to Azure Blob Container is via SAS Tokens only, provided by Mobilewalla.

•

Cloud Storage hosted by Client

•

In case of AWS S3, our preferred way is to access via AWS IAM role, provided by Client.

•

In case of Azure Blob or Google Cloud we support only the following options, to be provided by Client.

•

SAS Tokens for Azure Blob

•

Service Account Key (JSON Key) for Google Cloud Storage.

3.	Supplemental Terms and Conditions (if any):

This Statement of Work may be executed in one or more counterparts, each of which will be deemed an original but all of which together will constitute one and the same instrument. Counterparts may be delivered via facsimile, electronic mail (including PDF), or other transmission method and any counterpart so delivered shall be deemed to have been duly and validly delivered and be valid and effective for all purposes.

IN WITNESS WHEREOF, the parties have executed this Statement of Work as of the date set forth above.


Accepted by:						Accepted by:
MOBILEWALLA, Inc.						Client Name:


By:		By:
Authorized Signature		Authorized Signature

Jay D. Clark
Name (Please Print or Type)		Name (Please Print or Type)

COO
Title	Title

EXHIBIT B – DATA PROTECTION ADDENDUM

This Data Protection Addendum (“DPA”) forms part of the Master Data License Agreement (the “Agreement”) between Client and Mobilewalla. All capitalized terms that are not expressly defined in this DPA will have the meanings given to them in the Agreement.

1.	Definitions.

For purposes of this DPA, the following terms and those defined within the body of this DPA apply.

“Business” has the meaning set forth in Section 1798.140(c) of the CCPA.

“Client Personal Data” means Personal Data provided by Client to Mobilewalla. The Client Personal Data and the specific uses of the Client Personal Data are detailed in Exhibit B-1 attached hereto.

“Controller” means: (i) the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the Processing of Client Personal Data and/or Licensed Data; and (ii) if either party also acts as a Business under the Agreement, a Business.

“Data Protection Laws” means all applicable data privacy and data protection laws, rules, regulations, and directives to which the Client Personal Data and/or Licensed Data are subject. To the extent applicable, Data Protection Laws shall include, but not be limited to, the California Consumer Privacy Act of 2018 (“CCPA”), the EU General Data Protection Regulation 2016/679 (“GDPR”), and the European Union Directive 2002/58/EC and all amendments and updates to them or as replaced or superseded from time to time.

“Data Subject” means the identified or identifiable natural person to whom Client Personal Data or Licensed Data relates.

“Licensed Data” has the meaning set forth in the Agreement.

“Personal Data” has the meaning assigned to the terms “personal data” or “personal information” under applicable Data Protection Laws.

“Personal Data Breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Client Personal Data attributable to Mobilewalla.

“Process” means any operation or set of operations which is performed on data or on sets of data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

“Processor” means: (i) the natural or legal person, public authority, agency or other body which Processes Client Personal Data on behalf of the Controller; and (ii) if Client also acts as a Business of Client Personal Data under the Agreement, a Service Provider.

“Service Provider” has the meaning set forth in Section 1798.140(v) of the CCPA.

“Standard Contractual Clauses” means the Annex to the Commission Implementing Decision (EU) 2021/914 of 4 June 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.

“Subprocessor” means Mobilewalla’s authorized vendors and third party service providers that Process Client Personal Data pursuant to the Agreement.

Client Personal Data. Client is the Controller of Client Personal Data, and Mobilewalla is a Processor of Client Personal Data. Client represents and warrants that it: (i) has collected Client Personal Data in accordance with Data Protection Laws; and (ii) may lawfully disclose Client Personal Data to Mobilewalla for the purposes contemplated under the Agreement. Where Mobilewalla Processes Client Personal Data, Mobilewalla will:

Process Client Personal Data in accordance with the Agreement, this DPA, or any other written instructions agreed upon by the parties. If Mobilewalla reasonably believes there is a conflict between Client’s instructions and applicable laws, Mobilewalla agrees, unless legally prohibited from doing so, to promptly inform the Client;

Ensure that any person authorized to Process Client Personal Data has committed themselves to confidentiality or is under an appropriate statutory obligation of confidentiality;

Allow Subprocessors to Process Client Personal Data provided that:

Mobilewalla makes available to Client a list of its Subprocessors upon request;

ii.

Where required by Data Protection Laws, Mobilewalla provides Client notice of any new Subprocessor and allows Client ten (10) calendar days to object. If Client has legitimate objections to the appointment of any new Subprocessor, the parties will work together in good faith to resolve the grounds for the objection;

iii.

Mobilewalla requires such Subprocessors to be bound by data protection obligations consistent with this DPA; and

iv.

Mobilewalla remains responsible for its Subprocessors’ failure to perform their obligations with respect to the Processing of Client Personal Data;

Provide reasonable assistance to Client in fulfilling Client’s compliance obligations under Data Protection Laws including, but not limited to, Articles 15 – 22 and 35 – 36 of the GDPR, insofar as this is possible;

To the extent legally permitted: (i) promptly notify Client in writing upon receipt of an order, demand, or document purporting to request, demand or compel the production of Client Personal Data to any third party, including, but not limited to the United States government for surveillance and/or other purposes; and (ii) not disclose Client Personal Data to the third party without providing Client at least forty-eight (48) hours’ notice, so that Client may, at its own expense, exercise such rights as it may have under applicable laws to prevent or limit such disclosure.

Use commercially reasonable efforts to implement and maintain reasonable administrative, technical, and physical safeguards designed to protect Client Personal Data;

Notify Client in writing, without undue delay, upon becoming aware of a Personal Data Breach;

Where required by Data Protection Laws, make available to Client reasonable information necessary to demonstrate compliance with the obligations set forth in this Section 2 and allow for and contribute to audits conducted by Client or another auditor mandated by Client by completing a data protection questionnaire of reasonable length. Any information provided by Mobilewalla under this Section 2(h) shall be Mobilewalla’s Confidential Information; and

Delete all Client Personal Data in Mobilewalla’s possession following expiration or termination of the Agreement except to the extent Mobilewalla is required to retain some or all of the Client Personal Data under applicable laws.

Licensed Data. Subject to the terms of the Agreement, Client and Mobilewalla are independent Controllers of Licensed Data. Under no circumstances will Client and Mobilewalla be regarded as joint Controllers within the meaning set forth in GDPR Article 26. Client represents and warrants that it will Process Licensed Data in accordance with the Agreement, Data Protection Laws and any relevant self-regulatory frameworks. Where Client Processes Licensed Data, Client will:

Maintain a publicly available privacy notice that clearly and accurately describes its practices with respect to its Processing of Licensed Data;

Maintain a publicly available website or other digital property featuring an opt-out mechanism for Data Subjects who wish to opt out of having their Licensed Data Processed by Client and honor any such requests Client receives;

Be solely responsible for responding to any requests Client receives from Data Subjects exercising their rights in Licensed Data under applicable Data Protection Laws;

Use commercially reasonable efforts to implement and maintain reasonable administrative, technical, and physical safeguards designed to protect Licensed Data;

Notify Mobilewalla in writing, without undue delay, upon becoming aware of any unauthorized access, use, disclosure, or loss of Licensed Data (each a “Security Incident”). Client will be solely responsible for remediating any Security Incidents, including the provision of any notice to Data Subjects or regulatory authorities under Data Protection Laws. Notwithstanding the foregoing, if a Security Incident affects both parties, the parties agree to coordinate with respect to any notifications that are sent to Data Subjects or regulatory authorities regarding such Security Incident;

Allow for and contribute to audits, including inspections, conducted by the Mobilewalla or another auditor mandated by Mobilewalla; and

Promptly remediate any Processing of Licensed Data that Mobilewalla reasonably believes violates the Agreement or Data Protection Laws.

4.	International Transfers of Data.

Data Transfer Impact Assessment Questionnaire. Each party agrees that it has provided true, complete, and accurate responses to the Data Transfer Impact Assessment Questionnaire attached hereto as Exhibit B – 2.

Client Personal Data transferred by Client to Mobilewalla. If Client Personal Data originating in the European Economic Area, Switzerland, and/or the United Kingdom is transferred by Client to Mobilewalla in a country that has not been found to provide an adequate level of protection under Data Protection Laws, the parties agree that the transfer shall be governed by Module Two’s obligations in the Standard Contractual Clauses as supplemented by Exhibit B – 3 attached hereto (“Controller to Processor Standard Contractual Clauses”), the terms of which are incorporated herein by reference.

Licensed Data transferred by Mobilewalla to Client. If Licensed Data originating in the European Economic Area, Switzerland, and/or the United Kingdom is transferred by Mobilewalla to Client in a country that has not been found to provide an adequate level of protection under Data Protection Laws, the parties agree that the transfer shall be governed by Module One’s obligations in the Standard Contractual Clauses as supplemented by Exhibit B – 3 attached hereto (“Controller to Controller Standard Contractual Clauses”), the terms of which are incorporated herein by reference.

Data Transfer Impact Assessment Outcome. Taking into account the information and obligations set forth in this Agreement and, as may be the case for a party, such party’s independent research, to the parties’ knowledge, the Client Personal Data and/or Licensed Data originating in the European Economic Area, Switzerland, and/or the United Kingdom that is transferred pursuant to the Standard Contractual Clauses incorporated by reference herein to a country that has not been found to provide an adequate level of protection under Data Protection Laws is afforded a level of protection that is essentially equivalent to that guaranteed by Data Protection Laws.

Data Protection Questionnaire. Prior to the effective date and not more than twice per year thereafter upon Mobilewalla’s request, Client will complete a written data protection questionnaire provided by Mobilewalla or a third party on Mobilewalla’s behalf regarding Client’s data protection and business practices in relation to Client’s Processing or proposed Processing of Client Personal Data and/or Licensed Data. Client will reasonably cooperate with such inquiries, including by providing evidence of its compliance with the Agreement and answering follow-up questions as Mobilewalla may have in relation to Client’s responses.

Disputes, Claims, or Investigations. In the event of a dispute, claim, or investigation brought by a Data Subject or any regulatory authority against either or both parties concerning the Processing of Client Personal Data or Licensed Data under the Agreement, the parties will inform each other about any such disputes, claims, or investigations and will cooperate with and provide support to each other with a view to resolving them within a reasonable time.

Changes in Data Protection Laws. If an amendment to this DPA is required or otherwise advisable in order to comply with Data Protection Laws, Mobilewalla may provide an amendment to this DPA with the required changes to Client. Both parties will work together in good faith to promptly execute a mutually agreeable amendment to this DPA reflecting the requirements.

Indemnity. Without limiting any indemnification obligations set forth in the Agreement, Client agrees to indemnify, hold harmless and reimburse Mobilewalla for any and all compensation, damages, losses, fees (including attorneys’ fees), or costs incurred as a result of Client’s breach of this DPA, provided that: (i) Mobilewalla promptly notifies Client of such claim; (ii) Mobilewalla provides reasonable cooperation and assistance to Client in defense of such claim, at Client’s expense; and (iii) Client shall not settle any claim without Mobilewalla’s written approval, which may not be unreasonably withheld. Client’s obligations under this DPA shall not be subject to any limitation or exclusion of liability provision in the Agreement.

9.	Conflict. If and to the extent language in this DPA or any of its Exhibits conflicts with the Agreement, this DPA shall control with respect to any disputes arising a from party’s obligations under this DPA or Data Protection Laws.

EXHIBIT B – 1

CLIENT PERSONAL DATA – PROCESSING DETAILS

The following table sets forth the processing details for Client Personal Data as required by Article 28(3) of the GDPR:


1.1 Subject Matter of Processing		The Processing will involve Processing for the performance of the Agreement.
1.2 Duration of Processing		The Processing will continue until the expiration or termination of the Agreement.
1.3 Categories of Data Subjects		Data Subjects whose Client Personal Data is Processed pursuant to the Agreement including, but not limited to, prospects, customers, users or visitors of Clients (who are natural persons).
1.4 Nature and Purpose of Processing		The purpose of Processing of Client Personal Data is the performance the Agreement.
1.5 Types of Client Personal Data		Client Personal Data that is Processed pursuant to the Agreement including, but not limited to, online advertising identifiers (notably mobile device IDs).
1.6 Special Categories of Data (if appropriate)		N/A.

EXHIBIT B – 2

DATA TRANSFER IMPACT ASSSESMENT QUESTIONNAIRE

This Exhibit B – 2 forms part of the DPA. Capitalized terms not defined in this Exhibit B – 2 have the meaning set forth in the DPA.

Part 1 – Mobilewalla Responses: Part 1 relates to transfers of Client Personal Data received by Mobilewalla and will be completed by Mobilewalla.

1.	What countries will Client Personal Data that is transferred outside of the European Economic Area, Switzerland, and/or the United Kingdom be stored in or accessed from? If this varies by region, please specify each country for each region.

Answer: United States or Singapore

2.	What are the categories of data subjects whose Client Personal Data will be transferred outside of the European Economic Area, Switzerland, and/or the United Kingdom?

Answer: Data Subjects whose Client Personal Data is Processed pursuant to the Agreement including, but not limited to, prospects, customers, users or visitors of Client (who are natural persons).

3.	What are the categories of Client Personal Data transferred outside of the European Economic Area, Switzerland, and/or the United Kingdom?

Answer: Client Personal Data that is Processed pursuant to the Agreement including, but not limited to, online advertising identifiers (notably mobile device IDs).

Will any Client Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, or biometric data for the purpose of uniquely identifying a natural person, data concerning health or a person’s sex life or sexual orientation, or data relating to criminal convictions and offences be transferred outside of the European Economic Area, Switzerland, and/or the United Kingdom? If so, are there any 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?

Answer: Not to Mobilewalla’s knowledge.

5.	What business sector is Mobilewalla involved in?

Answer: Analytics, Modeling and advertising services.

6.	Broadly speaking, what are the services to be provided and the corresponding purposes for which Client Personal Data is transferred outside of the European Economic Area, Switzerland, and/or the United Kingdom?

Answer: Mobilewalla provides analytics and advertising services. Client Personal Data may be transferred outside of the European Economic Area, Switzerland, and/or the United Kingdom in order to provide the Services.

7.	What is the frequency of the transfer of Client Personal Data outside of the European Economic Area, Switzerland, and/or the United Kingdom? E.g., is Client Personal Data transferred on a one-off or continuous basis?

Answer: Client will determine how frequently it transfers Client Personal Data to Mobilewalla.

8.	What is the period for which the Client Personal Data will be retained, or, if that is not possible, the criteria used to determine that period?

Answer: Client Personal Data is retained in accordance with the Agreement and instructions from the Client.

9.	Please list the Subprocessors that will have access to Client Personal Data that is transferred outside of the European Economic Area, Switzerland, and/or the United Kingdom:


Name of Subprocessor	Subject matter, nature, and duration of processing	Location (Country)	Adequacy Mechanism Supporting Transfer
[MW to complete].

10.

Is Mobilewalla subject to any laws in a country outside of the European Economic Area, Switzerland, and/or the United Kingdom where Client Personal Data is stored or accessed from that would interfere with Mobilewalla fulfilling its obligations under the Standard Contractual Clauses? For example, FISA Section 702. If yes, please list these laws.

Answer: As of the effective date of the Agreement, no court has found Mobilewalla to be eligible to receive process issued under the laws contemplated by Question 10, including FISA Section 702 and no such court action is pending.

11.	Has Mobilewalla ever received a request from public authorities for information pursuant to the laws contemplated by Question 10 above (if any)? If yes, please explain.

Answer: No.

12.	Has Mobilewalla ever received a request from public authorities for Personal Data of individuals located in European Economic Area, Switzerland, and/or the United Kingdom? If yes, please explain.

Answer: No.

Part 2 – Client Responses: Part 2 relates to transfers of Licensed Data received by Client and will be completed by Client.

1.	What countries will Licensed Data that is transferred outside of the European Economic Area, Switzerland, and/or the United Kingdom be stored in or accessed from? If this varies by region, please specify each country for each region.

Answer: [Client to insert response].

2.	What are the categories of data subjects whose Licensed Data will be transferred outside of the European Economic Area, Switzerland, and/or the United Kingdom?

Answer: Data subjects whose Licensed Data is provided by Mobilewalla to Client under the Agreement.

3.	What are the categories of Licensed Data transferred outside of the European Economic Area, Switzerland, and/or the United Kingdom?

Answer: Licensed Data that is provided by Mobilewalla to Client under the Agreement including, but not limited to, online advertising identifiers (notably mobile device IDs).

Will any Licensed Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, or biometric data for the purpose of uniquely identifying a natural person, data concerning health or a person’s sex life or sexual orientation, or data relating to criminal convictions and offences be transferred outside of the European Economic Area, Switzerland, and/or the United Kingdom? If so, are there any 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?

a. Answer: [Client to insert response].

5.	What business sector is Client involved in?

Answer: [Client to insert response].

6.	What is the nature of Client’s Processing and the purposes for which Licensed Data is transferred outside of the European Economic Area, Switzerland, and/or the United Kingdom?

Answer: The Permitted Uses set forth in the Agreement.

7.	What is the frequency of the transfer of Licensed Data outside of the European Economic Area, Switzerland, and/or the United Kingdom? E.g., is Licensed Data transferred on a one-off or continuous basis?

Answer: Licensed Data will be transferred by Mobilewalla to Client in accordance with the standard functionality of Mobilewalla’s services or as otherwise agreed upon by the parties.

8.	What is the period for which the Licensed Data will be retained, or, if that is not possible, the criteria used to determine that period?

Answer: Licensed Data is retained in accordance with the Agreement.

9.	Please list the subprocessors that will have access to Licensed Data that is transferred outside of the European Economic Area, Switzerland, and/or the United Kingdom:


Name of Subprocessor	Subject matter, nature, and duration of processing	Location (Country)	Adequacy Mechanism Supporting Transfer
[Client to insert response].

10.

Is Client subject to any laws in a country outside of the European Economic Area, Switzerland, and/or the United Kingdom where Licensed Data is stored or accessed from that would interfere with Client fulfilling its obligations under the Standard Contractual Clauses? For example, FISA Section 702. If yes, please list these laws.

Answer: [Client to insert response].

11.	Has Client ever received a request from public authorities for information pursuant to the laws contemplated by Question 10 above (if any)? If yes, please explain.

Answer: [Client to insert response].

12.	Has Client ever received a request from public authorities for Personal Data of individuals located in European Economic Area, Switzerland, and/or the United Kingdom? If yes, please explain.

Answer: [Client to insert response].

EXHIBIT B – 3

ADDITIONAL TERMS FOR THE STANDARD CONTRACTUAL CLAUSES

This Exhibit B – 3 forms part of the DPA. Capitalized terms not defined in this Exhibit B – 3 have the meaning set forth in the DPA or the Standard Contractual Clauses.

The parties agree that the following terms will supplement the Standard Contractual Clauses:

Supplemental Terms. The parties agree that the following terms shall supplement the Standard Contractual Clauses: (i) a new Clause 1(e) is added the Standard Contractual Clauses which shall read: “To the extent applicable hereunder, these Clauses also apply mutatis mutandis to the Parties’ processing of personal data that is subject to the applicable data protection laws of Switzerland and/or the United Kingdom. Where applicable, references to EU Member State law or EU supervisory authorities shall be modified to include the appropriate reference under Swiss and/or United Kingdom law as it relates to transfers of personal data that are subject to such laws.”; (ii) the optional text in Clause 7 is deleted; (iii) under Module Two, Option 1 in Clause 9 is struck and Option 2 is kept, and Mobilewalla must provide notice of the new Subprocessor in accordance with Section 2(c)(ii) of the DPA; (iv) the optional text in Clause 11 is deleted; and (v) in Clauses 17 and 18, the governing law and the competent courts are those of Ireland (for EEA transfers), Switzerland (for Swiss transfers), or England and Wales (for UK transfers).

2.	Annex I. Annex I shall read as follows:

A. List of Parties

Data Exporter (Module One):

Name: Mobilewalla.

Address: As set forth in the Notices section of the Agreement.

Contact person’s name, position, and contact details: As set forth in the Notices section of the Agreement.

Activities relevant to the data transferred under these Clauses: As set forth in Exhibit B – 2.

Role: Controller.

Data Importer (Module One):

Name: Client.

Address: As set forth in the Notices section of the Agreement.

Contact person’s name, position, and contact details: As set forth in the Notices section of the Agreement.

Activities relevant to the data transferred under these Clauses: As set forth in Exhibit B – 2.

Role: Controller.

Data Exporter (Module Two):

Name: Client.

Address: As set forth in the Notices section of the Agreement.

Contact person’s name, position, and contact details: As set forth in the Notices section of the Agreement.

Activities relevant to the data transferred under these Clauses: As set forth in Exhibit B – 2.

Role: Controller.

Data Importer (Module Two):

Name: Mobilewalla.

Address: As set forth in the Notices section of the Agreement.

Contact person’s name, position, and contact details: As set forth in the Notices section of the Agreement.

Activities relevant to the data transferred under these Clauses: As set forth in Exhibit B – 2.

Role: Processor.

B. Description of the Transfer (Module One): As set forth in Exhibit B – 2, Part Two. (For clarity, each response required in Annex I, Section B shall be populated with the foregoing.)

B. Description of the Transfer (Module Two): As set forth in Exhibit B – 2, Part One. (For clarity, each response required in Annex I, Section B shall be populated with the foregoing.)

C. Competent Supervisory Authority (Module One and Module Two): The supervisory authority mandated by Clause 13. If no supervisory authority is mandated by Clause 13, then the Irish Data Protection Commission (DPC), and if this is not possible, then as otherwise agreed by the parties consistent with the conditions set forth in Clause 13.

3.	Annex II. Annex II shall read as follows:

(Module One and Module Two): Data importer will use commercially reasonable efforts to implement and maintain reasonable administrative, technical, and physical safeguards designed to protect personal data in accordance with the DPA.

Pursuant to Module Two, Clause 10(b), data importer will provide data exporter assistance with data subject requests in accordance with the DPA.

Clarifying Terms for the Controller to Processor Standard Contractual Clauses (Module Two). The parties agree that: (i) the certification of deletion required by Clause 8.5 and Clause 16(d) of the Controller to Processor Standard Contractual Clauses will be provided upon Client’s written request; (ii) the measures Mobilewalla is required to take under Clause 8.6(c) of the Controller to Processor Standard Contractual Clauses will only cover Mobilewalla’s impacted systems; (iii) the audit described in Clause 8.9 of the Controller to Processor Standard Contractual Clauses shall be carried out in accordance with Section 2(h) of the DPA; (iv) where permitted by Data Protection Laws, Mobilewalla may engage Subprocessors using European Commission Decision C(2010)593 Standard Contractual Clauses for Controllers to Processors or any other lawful adequacy mechanism and such use of Subprocessors shall not be considered a breach of Clause 9 of the Controller to Processor Standard Contractual Clauses; (v) the termination right contemplated by Clause 14(f) and Clause 16(c) of the Controller to Processor Standard Contractual Clauses will be limited to the termination of the Controller to Processor Standard Contractual Clauses, in which case, the corresponding Processing of Client Personal Data affected by such termination shall be discontinued unless otherwise agreed by the parties; (vi) unless otherwise stated by Mobilewalla, Client will be responsible for communicating with data subjects pursuant to Clause 15.1(a) of the Controller to Processor Standard Contractual Clauses; (vii) the information required under Clause 15.1(c) will be provided upon Client’s written request; and (viii) notwithstanding anything to the contrary, Client will reimburse Mobilewalla for all costs and expenses incurred by Mobilewalla in connection with the performance of Mobilewalla’s obligations under Clause 15.1(b) and Clause 15.2 of the Controller to Processor Standard Contractual Clauses without regard for any limitation of liability set forth in the Agreement.

5.	Signature. Each party’s signature to the Agreement shall be considered a signature to the Standard Contractual Clauses to the extent that the Standard Contractual Clauses apply hereunder.

EXHIBIT-C

LOGO

Mobilewalla Customer Data Needs and Use Survey

Overview. Mobilewalla maintains high ethical data collection and use standards. As part of our efforts, we endeavor to understand and tailor our business to meet our client’s specific needs while also complying with global laws and preventing use of our data and services for discriminatory purposes or safety-threatening purposes. This survey is intended as a way for us to better deliver on your expectations.

Instructions: Please answer the questions below to provide further information on your intended data needs and uses for the data provided by Mobilewalla. For each question, please check all answers that apply.

Data Elements. Which of the following data elements, if any, do you intend to receive from Mobilewalla:


Mobilewalla Data Elements – Personal and Sensitive Data

☐	Mobile Advertising Identifier (MAID)	☐	Gender

☐	Latitude/Longitude	☐	Income Level

☐	Work or Home Location (inferred)	☐	Age

			Other sensitive data elements (please describe below)

Data Use Type. For which of the following purposes do you plan to use the data?


Audiences/Targeting/Other

☐		Mobile marketing for customer acquisition

☐		Social media marketing

☐		Lookalike marketing

☐		Targeting offers based on... (select all that apply – and provide a summary description)

☐		• user preferences (e.g., music lover, outdoor enthusiast, shopper)

☐		• user characteristics (e.g., demographic marketing for restaurants or products or services)

☐		• Precise historical location (within 16 feet)

☐		• Approximate historical location (more than 16 feet)

		Please provide additional detail regarding your uses based on the checked boxes above

☐		Other (please describe below)

Data Enrichment

☐		Completing user profiles of existing customers or pre-existing relationships

☐		Linking devices with other customer data of existing customers or pre-existing relationships


☐		Identifying and engaging prospects for new customer acquisition

☐		Tailoring of services to user preferences or characteristics (e.g., new product launches, personalized offers based on preferences and characteristics)

☐		Other (please describe below)

Analytics

☐		Conducting trend analysis (over time) (e.g., purchase trends for new phone models; foot traffic at potential retail location)

☐		Marketing campaign effectiveness determination (e.g., visits to dining or retail location based on targeted advertising)

☐		Developing aggregated analysis (e.g., telecom carrier or phone model market share analysis)

☐		Other (please describe below)

AI/Predictive Modeling

☐		Develop AI/ML predictive models

☐		Train/enhance predictive models

☐		Other (please describe below)

Data Sharing. Please indicate with which of the parties below you intend to share the data?


External

☐		Clients/Customers

☐		Partners / Joint Venturers

☐		Sharing U.S. data with non-U.S. entities

☐		Public (e.g., blog, news article)

☐		Other (please describe below)

Other: Please provide any other comments or description of intended data use.

Attestation: I attest that the responses provided above are comprehensive and accurate.


Client Legal Entity Name

Client Name

Client Signature

Date