Data Processing Agreement

Version 1.0 · June 2026

This Data Processing Agreement ("DPA") forms part of the agreement between AnnexPass OÜ ("Processor") and the customer ("Controller") for the provision of AnnexPass software services.

1. Subject matter

Processor processes personal data on behalf of Controller in connection with battery passport compliance workflows, supplier due diligence, and document storage.

2. Data categories

  • User account data (name, email, role)
  • Supplier contact information
  • Uploaded compliance documents
  • Audit trail metadata

3. Subprocessors

Controller authorises use of subprocessors listed on the Trust centre. Processor will notify Controller of material changes.

4. Data location

All customer data processed and stored within the European Economic Area unless otherwise agreed in writing.

This is a placeholder DPA for engineering and sales enablement. Final version requires legal counsel review before customer signature.

AnnexPass (AnnexPass OÜ) provides software tools to support compliance workflows. Customers remain the economic operator responsible for regulatory compliance. Not legal advice.