Safe API Data Processing Agreement

Last updated: Oct, 2025

This Data Processing Agreement ("Agreement") forms part of the General API License Terms and Conditions ("Terms") between

Any entity ("Developer") signing up via https://developer.safe.global

And

Safe Labs GmbH
Unter den Linden 10, 10117 Berlin
Germany
as "data processor" or further "Safe Labs"

(A) The Parties seek to implement a data processing agreement that complies with the requirements of the current legal framework in relation to data processing and with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation).

(B) The Parties wish to lay down their rights and obligations.

1) Definitions and Interpretation

Unless otherwise defined herein, capitalized terms and expressions used in this Agreement shall have the following meaning:

• "Agreement" means this Data Processing Agreement and all Schedules;

• "Personal Data" means any Personal Data Processed by Safe Labs on behalf of Developer pursuant to or in connection with the Terms;

• "Data Protection Laws" means the Data Protection Laws of the European Union, including, but not limited to the GDPR, and, to the extent applicable, the data protection or privacy laws of any other country applicable to the Processing under the Principal Agreement;

• "EEA" means the European Economic Area;

• "GDPR" means EU General Data Protection Regulation 2016/679;

• "EU Data Protection Laws" means the applicable data protection laws such as the GDPR and the national implementations of the GDPR.

• "Data Transfer" means:

  • a transfer of Company Personal Data from Developer to Safe Labs;

  • an onward transfer of Company Personal Data from Safe Labs to a Subcontracted Processor, or between two establishments of a Contracted Processor, in each case, where such transfer would be prohibited by Data Protection Laws (or by the terms of data transfer agreements put in place to address the data transfer restrictions of Data Protection Laws);

• "International Data Transfer" means: a transfer of Company Personal Data to countries outside the EU and/or the European Economic Area (EEA)

• "Subprocessor" or "Subcontracted Processor" means any person appointed by or on behalf of Safe Labs to process Personal Data on behalf of Safe Labs in connection with the Agreement

• The terms, "Commission", "processor", "Data Subject", "Member State", "Personal Data", "Personal Data Breach", "Processing" and "Supervisory Authority" shall have the same meaning as in the GDPR.

2) Subject matter and processing activities

Subject matter, nature, and purpose of processing
The subject-matter of the processing shall be the provision of the API service hosted by Safe Labs and available via REST as described in the Terms. The nature and purpose of the processing activities is the collection of login credentials and IP addresses for the purpose of provision of the service and system security and integrity maintenance respectively.
The processor shall carry out the above processing on behalf of the controller.

Duration of the processing
For the above-mentioned activities, the processing of personal data is planned for the duration of the relationship between Safe Labs and Developer.

IP addresses are stored by Safe Labs for 30 days to support operational needs and then automatically deleted.

Categories of data subjects
Users of the Dashboard
End-users of the Developer's Services

Category of personal data
The categories of personal data processed are:

• Email address

• IP addresses

3) Processor obligations

A) Compliance with instructions

Safe Labs shall comply with all applicable Data Protection Laws in the Processing of Developer Personal Data; and shall not process Developer Personal Data other than on Developer's documented instructions.

B) Confidentiality

Safe Labs shall take reasonable steps to ensure the reliability of any employee, agent or contractor or any subprocessor who may have access to the Controller Personal Data, ensuring in each case that access is strictly limited to those individuals and that all such individuals are subject to obligations of confidentiality.

C) Security

1. Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity to the rights and freedoms of natural persons, Safe Labs shall in relation to the Company Personal Data implement appropriate technical and organizational measures to ensure a level of security appropriate to that risk. A list of applicable measures is indicated in Annex B of this Agreement;

2. In assessing the appropriate level of security, the Processor shall take account in particular of the risks that are presented by the processing, in particular from the perspective of the risk of a Personal Data Breach.

D) Personal Data Breach

1. The Processor shall notify Developer without undue delay upon Safe Labs becoming aware of a Personal Data Breach affecting Developer's personal data.

2. Safe Labs shall cooperate with Developer and take reasonable commercial steps as are directed by Safe Labs to assist in the investigation, mitigation and remediation of such Personal Data Breach.

E) Deletion or return of Company Personal Data

Safe Labs shall promptly and in any event within 30 business days of the date of receiving the request from the company to delete their personal data or on cessation of any activities involving the Processing of Developer Personal Data, whichever is earlier (the "Cessation Date"), delete and, if requested, procure the deletion of all copies of those Developer Personal Data. Where deletion is complex, an additional 30 days can be granted by Developer if duly justified.

F) Data Protection Impact Assessment and Prior Consultation

Safe Labs shall provide reasonable assistance to Developer with any data protection impact assessments, and prior consultations with Supervising Authorities or other competent data privacy authorities, which Company reasonably considers to be required by article 35 or 36 of the GDPR or equivalent provisions of any other Data Protection Law, in each case solely in relation to Processing of Company Personal Data by, and taking into account the nature of the Processing and information available to, the Contracted Processors.

4) Data subject rights

1. Taking into account the nature of the Processing, Safe Labs shall assist Developer by implementing appropriate technical and organisational measures, insofar as this is possible, for the fulfilment of their obligations, as reasonably understood by Company, to respond to requests to exercise Data Subject rights under the Data Protection Laws.

2. The Processor shall:
   - notify Developer if it receives a request from a Data Subject under any Data Protection Law in respect of Company Personal Data; and
   - ensure that it does not respond to that request except on the documented instructions of Developer.

5) Subprocessing

Developer hereby gives a general authorisation to involve subprocessors to process personal data under this Agreement. In the case Safe Labs intends to update the list of subprocessors engaged, they must inform Developer within 30 days and provide Developer with the opportunity to object against the intended changes.

The parties mutually acknowledge and agree that the Processor currently commissions sub-processors on the condition of a contractual agreement in accordance with Article 28 paragraph 4 GDPR.

6) Audit rights

Subject to this section 10, Safe Labs shall make available to Developer on request all information necessary to demonstrate compliance with this Agreement, and shall allow for and contribute to audits, including inspections, by the Company or an auditor mandated by the Company in relation to the Processing of the Company Personal Data by the Contracted Processors.

7) International Data transfer

Safe Labs shall not transfer or authorize the transfer of Company Personal Data to countries outside the EU and/or the European Economic Area (EEA) without the prior written consent of Developer. If personal data processed under this Agreement is transferred from a country within the European Economic Area to a country outside the European Economic Area, the Parties shall ensure that the personal data are adequately protected. To achieve this, the Parties shall, unless agreed otherwise, rely on EU approved standard contractual clauses for the transfer of personal data.

8) Governing Law and Jurisdiction

This Agreement is governed by the laws of the Federal Republic of Germany.

Any dispute arising in connection with this Agreement, which the Parties will not be able to resolve amicably, will be submitted to the exclusive jurisdiction of the courts of Berlin (Germany).

This Agreement is entered into with effect simultaneously with the Developer accepting the Terms.

ANNEX A - Subject matter of the processing

Subject-matter of the processing:

The provision of the API service hosted by Safe Labs and available via REST as described in the Terms. The nature and purpose of the processing activities is the collection of login credentials and IP addresses for the purpose of provision of the service and system security and integrity maintenance respectively.

Duration of the processing

Duration of the relationship between Safe Labs and Developer.

IP addresses are stored by Safe Labs for 30 days to support operational needs and then automatically deleted.

Categories of data subjects

• Users of the Dashboard

• End-users of the Developer's Services

Category of personal data:

• Email address

• IP addresses

ANNEX B - Security Measures

The Processor implements the following security measures

ANNEX C - List of Subprocessors

The Processor shall not engage other processors without general written authorisation from the Controller.

Within the scope of the processing at hand, the Processor is authorised to transfer personal data outside of the EEA subject to conditions of Section 4 and 6.