PUBLISHED DOCUMENT Version 1.0.2

Data Processing Addendum

Published data processing addendum for MyCompany.LTD, a product operated by 1STNET MARKETING LTD.

Effective date: 7 August 2026 · Last updated: 7 August 2026 · Version 1.0.2

This Data Processing Addendum applies when incorporated into or accepted as part of the applicable MyCompany.LTD customer agreement. Annex details are confirmed in that agreement.

This document does not constitute legal advice to you; you should take your own advice on how it applies to your organisation.

01Purpose

This Data Processing Addendum (the "DPA") describes how 1STNET MARKETING LTD processes personal data on behalf of its customers in connection with MyCompany.LTD. It is designed to support UK GDPR-aligned workflows and forms part of the agreement between the customer and 1STNET MARKETING LTD where we process personal data as a processor.

02Parties and roles

For the purposes of this DPA, the customer is the controller of the personal data within its workspace, and 1STNET MARKETING LTD is the processor that processes that personal data on the customer's documented instructions. Where 1STNET MARKETING LTD processes personal data for its own purposes, it does so as a controller under our Privacy Policy.

03Subject matter

The subject matter of the processing is the provision of the MyCompany.LTD platform and related services to the customer, including the hosting and processing of customer workspace data as necessary to deliver those services.

04Duration

Processing continues for the duration of the customer agreement and for any additional period required to return or delete personal data, or as otherwise required by applicable law.

05Nature and purpose of processing

The nature and purpose of the processing is to provide, operate, maintain, secure, and support the platform and services for the customer, including storage, organisation, retrieval, transmission, and other operations performed on personal data in accordance with the customer's instructions and the customer agreement.

06Categories of data subjects

The categories of data subjects may include the customer's authorised users, employees, contractors, clients, prospects, contacts, invited client-portal users, and other individuals whose personal data the customer chooses to process within its workspace.

07Categories of personal data

The categories of personal data may include identity and contact details, business and account information, communications and correspondence, usage data, and any other personal data that the customer chooses to include within its workspace. The customer is responsible for the personal data it submits for processing.

08Processor obligations

We will: process personal data only on the customer's documented instructions, including with regard to international transfers, unless required by law; ensure that persons authorised to process personal data are bound by appropriate confidentiality obligations; implement appropriate technical and organisational measures; assist the customer, taking into account the nature of processing, in responding to data subject requests and meeting its obligations; and make available information necessary to demonstrate compliance.

09Customer obligations

The customer is responsible for ensuring it has a valid lawful basis and any necessary consents or notices for the personal data it processes within its workspace, that its instructions to us are lawful, and that its use of the platform complies with applicable data protection law. The customer must not provide special category data except as agreed and lawfully permitted.

10Security measures (TOMs)

We maintain technical and organisational measures (TOMs) designed to protect personal data against unauthorised or unlawful processing and against accidental loss, destruction, or damage. The applicable TOMs are confirmed in writing in the customer agreement and may be updated provided that the level of protection is not materially reduced. The measures include:

  • access controls and role-based permissions
  • authentication controls and least-privilege access
  • encryption in transit where available
  • secure hosting and network controls
  • backups and restoration practices
  • monitoring and logging
  • vulnerability management and update practices
  • incident response process
  • staff confidentiality obligations

Final technical and organisational measures must be verified against the production implementation before public launch.

11Subprocessors

The customer authorises us to engage subprocessors to support the provision of the services. We engage subprocessors under written terms that impose data protection obligations consistent with this DPA. We will notify the customer of intended changes to subprocessors so that the customer has the opportunity to object on reasonable grounds. The final subprocessor list is confirmed in the customer agreement; no named subprocessor is asserted here.

12International transfers

Where personal data is transferred outside the United Kingdom, we will put in place an appropriate transfer mechanism, such as relevant adequacy regulations or standard contractual clauses with additional safeguards as appropriate. The applicable transfer mechanisms are confirmed in the customer agreement.

13Data subject rights

Taking into account the nature of the processing, we will provide reasonable assistance to enable the customer to respond to requests from data subjects exercising their rights under applicable data protection law. Where we receive such a request directly, we will, where appropriate, direct the individual to the customer.

14Personal data breaches

We will notify the customer without undue delay after becoming aware of a personal data breach affecting the customer's personal data, and will provide reasonable information and assistance to help the customer meet its own notification and reporting obligations.

15Return or deletion

On termination or expiry of the customer agreement, we will, at the customer's choice, return or delete the customer's personal data, except where we are required to retain it by applicable law. Backups are deleted in the ordinary course in accordance with our retention practices.

16Audit and information

We will make available to the customer information reasonably necessary to demonstrate compliance with this DPA and will allow for and contribute to audits, including inspections, conducted by the customer or an authorised auditor, subject to reasonable notice, confidentiality, and scope as set out in the customer agreement.

17Liability, precedence and governing law

This DPA supplements the customer agreement and our Terms and Conditions. Where there is a conflict on data protection matters, this DPA prevails. Liability under this DPA is subject to the limitations and exclusions set out in the Terms and Conditions and the customer agreement. This DPA is governed by the laws of England and Wales, and the courts of England and Wales have exclusive jurisdiction.

18Term and termination

This DPA takes effect for as long as we process personal data on the customer's behalf and terminates automatically on completion of the return or deletion of that personal data in accordance with section 15.

19Contact

For any questions about this DPA or our processing of personal data, please contact us at hello@1stnetmarketing.com or on 0800 593 0369. Final subprocessors, technical and organisational measures, and international transfer mechanisms are confirmed in the customer agreement.

1STNET MARKETING LTD

Company number: 15261922 · Registered in England and Wales

Registered office: 1a Babington Road, Barrow Upon Soar, Loughborough, England, LE12 8NH

Email: hello@1stnetmarketing.com · Phone: 0800 593 0369

Support: Monday–Friday, 10:00–18:00 GMT, excluding UK bank holidays

This document is published by 1STNET MARKETING LTD and applies to MyCompany.LTD. Version 1.0.2 · Effective 7 August 2026 · Last updated 7 August 2026. It does not constitute legal advice to you; you should take your own advice on how it applies to your organisation.