This Data Processing Agreement ("DPA") is an integral part of the Terms of Service between Travchis LLC, 651N Broad st, suite 201, Middletown, DE, 19709 (doing business as ProxyWing), hereinafter referred to as "Provider," and the user of Provider's services, hereinafter referred to as "Client."

1. Definitions

2. Scope and Purpose

The Provider shall process Personal Data exclusively to deliver proxy services described in the service agreement with the Client. Provider agrees to process Personal Data strictly in compliance with Client's documented instructions unless required by applicable law.

3. Provider’s Obligations

Provider agrees to:

• — Process Personal Data only on the documented instructions of Client.
• — Ensure personnel with access to Personal Data have committed to confidentiality obligations.
• — Implement appropriate technical and organizational security measures to safeguard Personal Data against unauthorized processing and accidental loss.
• — Immediately notify Client of any known Data Breach involving Client’s Personal Data.
• — Assist Client in fulfilling its obligations under data protection regulations, including data protection impact assessments and responding to supervisory authorities.
• — Maintain accurate and detailed records of all processing activities concerning Personal Data.

4. Client’s Obligations

Client agrees to:

• — Ensure all Personal Data provided to Provider is collected and processed lawfully and transparently.
• — Provide clear and detailed written instructions for processing Personal Data.
• — Promptly inform Provider of any changes in data processing requirements or circumstances affecting the Personal Data processed.

5. Sub-processors

Provider may engage sub-processors under the following conditions:

• — Provider ensures each sub-processor complies with data protection obligations equivalent to those described in this DPA.
• — Provider provides prior written notification to Client of any intended changes to sub-processors, allowing the Client to object reasonably.

6. Data Transfers

Any transfers of Personal Data outside the Client’s jurisdiction will comply with applicable data protection regulations and will involve appropriate safeguards such as standard contractual clauses or equivalent measures.

7. Duration and Termination

This DPA remains in effect for the duration of Provider’s services involving processing Personal Data on behalf of the Client. Upon termination or expiration, Provider shall, at the Client’s discretion, securely delete or return all Personal Data, unless retention is legally required.

8. Audit Rights

Provider agrees to make available to Client all necessary information to demonstrate compliance with this DPA and permit reasonable audits conducted by Client or authorized auditors, provided sufficient prior written notice and mutual agreement regarding audit details and scope.

9. Liability

Provider’s liability under this DPA shall be subject to the limitations and exclusions outlined in the primary Terms of Service agreement between Provider and Client, except where applicable data protection laws mandate otherwise.

10. Governing Law and Jurisdiction

This DPA shall be governed by the laws of the jurisdiction specified in the primary Terms of Service between Provider and Client. All disputes arising under this DPA shall be resolved according to the dispute resolution mechanisms outlined in the Terms of Service.

11. Amendments

Any amendments or modifications to this DPA must be documented in writing and signed by authorized representatives of both Provider and Client to be valid and binding.

Acceptance of services from ProxyWing constitutes acceptance of the terms and conditions outlined in this Data Processing Agreement.