Data Processing Addendum (DPA) – Viribuz Media, Inc

Last updated: 25 November 2025

This Data Processing Addendum (“DPA”) forms part of the Master Services Agreement, Insertion Order, or Terms of Service (“Agreement”) between:

Viribuz Media, Inc

175 2nd St S, Apt 1111

St Petersburg, FL 33701

United States

(“Processor”)

and the Client identified in the Agreement (“Controller”).

By signing the Agreement or using Viribuz Media services, Controller enters into this DPA.

1.

Definitions

Controller, Processor, Data Subject, Personal Data, Processing, and Personal Data Breach have the meanings given in the GDPR and CCPA.

GDPR means Regulation (EU) 2016/679.

SCCs means the EU Standard Contractual Clauses (Commission Implementing Decision 2021/914 – Module 2: Controller to Processor).

2.

Roles and Scope

Viribuz Media acts as Processor (or Service Provider under CCPA) when processing Personal Data on behalf of Controller for the purpose of delivering digital advertising and performance-marketing campaigns.

3.

Details of Processing

Nature and Purpose: Delivery, optimisation, and measurement of digital advertising campaigns
Data Subjects: End-users of Controller’s websites/apps (consumers)
Types of Personal Data: Advertising IDs (AAID/IDFA), IP address, cookie IDs, hashed email, city-level location, device and browser information
Duration: Term of the campaign + 90 days (unless otherwise instructed)

4.

Sub-processors

Controller authorises the sub-processors listed at https://www.viribuzmedia.com/subprocessors (updated in real time).

Processor will provide 30 days’ notice of any new sub-processor.

5.

Obligations of Processor

  • Process Personal Data only on Controller’s documented instructions
  • Ensure confidentiality of all persons authorised to process the data
  • Implement appropriate technical and organisational measures
  • Assist with data-subject requests, DPIAs, and breach notification
  • Delete or return all Personal Data at termination of services
  • Make available information necessary to demonstrate compliance

6.

Security Measures

  • Encryption in transit (TLS 1.3) and at rest (AES-256)
  • Multi-factor authentication enforced on all accounts
  • Continuous external vulnerability scanning (Intruder.io, CREST-accredited)
  • Immutable backups (AWS S3 Object Lock)
  • Incident response plan tested annually
  • Employee background checks and annual security training

7.

International Data Transfers

Transfers outside the EEA are governed by the EU Standard Contractual Clauses (Module 2), incorporated by reference:

Clause 7 (Docking clause): Applies
Clause 9(a) Option 2: General written authorisation
Clause 17: Laws of Ireland
Clause 18(b): Courts of Ireland

8.

CCPA/CPRA

Processor is a Service Provider. Processor does not sell or share Personal Information and does not use it outside the business purpose.

9.

Governing Law

This DPA is governed by the laws of the State of Florida.

10.

Execution

This DPA is effective upon acceptance of the Agreement and remains in force for the duration of the services.

VIRIBUZ MEDIA, INC

By: _____________________________________ Date: _________________

Name: Joshua Morris

Title: Chief Executive Officer

CLIENT

By signing the Agreement or using our services, Client accepts this DPA.

By: _____________________________________ Date: _________________

Name: __________________________________

Title: ___________________________________

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