Last updated: October 17, 2026

This document forms an integral part of Curately’s Terms of Service (the “ToS”), accepted by the Client at subscription.

Between the undersigned

CURATELY, a French société par actions simplifiée (SAS) with share capital of [À COMPLÉTER], having its registered office at 231 rue Saint-Honoré, 75001 Paris, France, registered with the Paris Trade and Companies Register under SIREN 106 302 532, represented by Anastassia Kokot Baïdoukova in her capacity as Présidente,

hereinafter “Curately” or “the Processor”,

and

the Client, as identified at subscription,

hereinafter “the Client” or “the Controller”.

Curately and the Client are together referred to as “the Parties” and individually as “the Party”.

Preamble

This Data Processing Agreement (the “DPA”) governs the processing of personal data carried out by Curately on behalf of the Client in the context of the provision of the Services, in accordance with Article 28 of Regulation (EU) 2016/679 (the “GDPR”).

The Client acts as data controller with respect to the personal data of its end-customers (“End-Customers”). Curately acts as processor.

1. Definitions

Capitalized terms used in this DPA have the meaning set out in the ToS or, failing that, in the GDPR (“personal data”, “processing”, “controller”, “processor”, “personal data breach”, “data subject”, etc.).

2. Roles of the Parties

2.1 The Client is the data controller with respect to the personal data of its End-Customers processed in the context of the Services.

2.2 Curately processes such data solely on behalf of the Client, on the Client’s documented instructions, and in accordance with this DPA.

3. Subject-matter, duration, nature and purpose of the processing

3.1 Curately processes personal data for the duration of the Client’s subscription to the Services, for the purpose of providing the Services (conversational strategy, sending of marketing, utility and service messages on the channels operated, recommendations, order tracking, continuous optimization).

3.2 A detailed description of the processing is set out in Annex 1.