Atlassian Data Processing Addendum
This Data Processing Addendum ("DPA") amends the terms and forms part of the Agreement (defined below) by and between
the customer as identified in the Agreement ("Customer") and the applicable Atlassian entity from which Customer is purchasing
Cloud Products ("Atlassian") and will be effective on the later of (i) the effective date of the Agreement; or (ii) the date bothparties execute this DPA in accordance with Section 1 below ("Effective Date"). All capitalized terms not defined in this DPA havethe meanings set forth in the Agreement.
1.

Instructions and Effectiveness
1.1.

2.

This DPA has been pre-signed on behalf of Atlassian. To enter into this DPA, Customer must:(a)

be a customer of the Cloud Products;(b)complete the signature block below by signing and providing all relevant information; and(c)submit the completed and signed DPA to Atlassian.

1.2.

This DPA will only be effective (as of the Effective Date) if executed and submitted to Atlassian accurately and in fullaccordance with Section 1. Where Customer makes any deletions or other revisions to this DPA, this DPA will benull and void.

1.3.

Customer signatory represents to Atlassian that he or she has the legal authority to bind Customer and is lawfully
able to enter into this DPA.

Data Protection
2.1.

Definitions: In this DPA, the following terms have the following meanings:(a)“Agreement” means the contract in place between Customer and Atlassian in connection with the purchaseof Cloud Products by Customer.

(b)“Applicable Data Protection Law” means U.S. Data Protection Law and European Data Protection Law thatare applicable to the processing of personal data under this DPA.

(c)“controller”, “processor”, “data subject”, “personal data” and “processing” (and “process”) have themeanings given in European Data Protection Law.

(d)

“Customer Personal Data” means any personal data provided by (or on behalf of) Customer to Atlassian inconnection with the Services, all as further described in Exhibit A, Annex 1(B), Part A of this DPA.

(e)“End Users” means an individual the Customer permits or invites to use the Cloud Products. For the avoidanceof doubt: (a) individuals invited by End Users, (b) individuals under managed accounts, and (c) individuals
interacting with a Cloud Product as Customer`s customers are also considered End Users.

(f)“Europe” means for the purposes of this DPA, the Member States of the European Economic Area (“EEA”),
the United Kingdom (“UK”) and Switzerland.

(g)“European Data Protection Law” means: (i) Regulation 2016/679 of the European Parliament and of theCouncil on the protection of natural persons with regard to the Processing of Personal Data and on the freemovement of such data (General Data Protection Regulation) (“EU GDPR”); (ii) in respect of the United
Kingdom the Data Protection Act 2018 and the EU GDPR as saved into United Kingdom law by virtue of Section
3 of the United Kingdom's European Union (Withdrawal) Act 2018 (“UK Data Protection Law”); (iii) the EU ePrivacy Directive (Directive 2002/58/EC); and (iv) the Swiss Federal Data Protection Act and its implementing
regulations (“Swiss DPA”), in each case as may be amended, superseded or replaced from time to time.

(h)“Privacy Shield Principles” means the Privacy Shield Principles (as supplemented by the Supplemental
Principles) contained in Annex II to the European Commission Decision C(2016)4176 of 12 July 2016 (as may
be amended, superseded or replaced).

(i)“Restricted Transfer” means a transfer (directly or via onward transfer) of personal data that is subject toEuropean Data Protection Law to a country outside Europe that is not subject to an adequacy decision by theEuropean Commission, or the competent UK or Swiss authorities (as applicable).

(j)“Security Incident” means any confirmed breach of security that leads to the accidental, or unlawfuldestruction, loss, alteration, unauthorized disclosure of or access to Customer Personal Data processed by1

Atlassian and/or its Sub-processors in connection with the provision of the Service. For the avoidance of
doubt, "Security Incident" does not include unsuccessful attempts or activities that do not compromise thesecurity of personal data, including unsuccessful login attempts, pings, port scans, denial of service attacks,
and other network attacks on firewalls or networked systems.
(k)“Services” means the provision of the Cloud Products by Atlassian to Customer pursuant to the Agreement.

(l)“special categories of personal data” or “sensitive data” means any Customer Personal Data (i) revealing
racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, (ii) thatis genetic data, biometric data processed for the purposes of uniquely identifying a natural person, data
concerning health, or data concerning a natural person's sex life or sexual orientation, and (iii) relating tocriminal convictions and offences.

(m) “Standard Contractual Clauses” or “EU SCCs” means the contractual clauses annexed to the European
Commission's Implementing Decision 2021/914 of 4 June 2021 on standard contractual clauses for thetransfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliamentand of the Council.

2.2.

(n)

“Sub-processor” means any processor engaged by Atlassian to assist in fulfilling its obligations with respect
to providing the Services pursuant to the Agreement or this DPA where such entity processes Customer
Personal Data. Sub-processors may include Atlassian’s affiliates or other third parties.

(o)“UK Addendum” means the International Data Transfer Addendum (version B1.0) issued by the Information
Commissioner's Office under S119(A) of the UK Data Protection Act 2018, as may be amended, superseded,or replaced from time to time.

(p)“U.S. Data Protection Law” means those data protection or privacy laws and regulations within the UnitedStates, including the California Consumer Privacy Act (as amended) (the “CCPA”), as applicable to Customer
Personal Data.

Relationship of the parties: Where Applicable Data Protection Law provides for the roles of “controller,”“processor,” and “sub-processor”:(a)Where Atlassian processes Customer Personal Data on behalf of Customer in connection with the Services,
Atlassian will process such personal data as a processor or Sub-processor on behalf of Customer (who, in turn,processes such personal data as a controller or processor) and this DPA will apply accordingly. A descriptionof such processing is set out in Exhibit A, Annex 1(B), Part A.

(b)

Where Atlassian processes personal data as a controller, as further detailed in Exhibit A, Annex 1(B), Part B,
Atlassian will process such personal data in compliance with Applicable Data Protection Law and only for the
purposes that are compatible with those described in Exhibit A, Annex 1(B), Part B. For these purposes, only
Sections 2.3 and 2.6 of this DPA will apply, to the extent applicable.

2.3.

Description of Processing: A description of the processing of personal data related to the Services, as applicable, isset out in Exhibit A. Atlassian may update the description of processing from time to time to reflect new products,
features or functionality comprised within the Services. Atlassian will update relevant documentation to reflect suchchanges.

2.4.

Customer Processing of Personal Data: Customer agrees that (i) it will comply with its obligations under Applicable
Data Protection Law in its processing of Customer Personal Data and any processing instructions it issues toAtlassian, and (ii) it has provided notice and obtained (or will obtain) all consents and rights necessary under
Applicable Data Protection Law for Atlassian to process personal data (including but not limited to any special
categories of personal data) and provide the Services pursuant to the Agreement (including this DPA).

2.5.

Atlassian Processing of Personal Data: When Atlassian processes Customer Personal Data in its capacity as aprocessor on behalf of the Customer, Atlassian will process the Customer Personal Data as necessary to perform its
obligations under the Agreement, and only in accordance with the documented lawful instructions of Customer (asset forth in the Agreement, in this DPA, or as directed by the Customer or Customer’s End Users through the Cloud
Products) (the “Permitted Purpose”). Atlassian will not retain, use, disclose or otherwise process the Customer
Personal Data for any purpose other than the Permitted Purpose except where otherwise required by law(s) thatare not incompatible with Applicable Data Protection Law, and will not “sell” the Customer Personal Data within
the meaning of the CCPA or otherwise. Atlassian will promptly inform Customer if it becomes aware that Customer's
processing instructions infringe Applicable Data Protection Law.

2

2.6.

Restricted transfers: The parties agree that when the transfer of personal data from Customer (as “data exporter”)
to Atlassian (as “data importer”) is a Restricted Transfer and Applicable Data Protection Law requires thatappropriate safeguards are put in place, the transfer will be subject to the Standard Contractual Clauses, which are
deemed incorporated into and form a part of this DPA, as follows:
(a)

(b)

In relation to transfers of Customer Personal Data protected by the EU GDPR and processed in accordancewith Section 2.2(a) of this DPA, the EU SCCs will apply, completed as follows:i.

Module Two or Module Three will apply (as applicable);ii.

in Clause 7, the optional docking clause will apply;iii.

in Clause 9, Option 2 will apply, and the time period for prior notice of Sub-processor changes will be
as set out in Section 2.10 of this DPA;

iv.

in Clause 11, the optional language will not apply;v.

in Clause 17, Option 1 will apply, and the EU SCCs will be governed by Irish law;vi.

in Clause 18(b), disputes will be resolved before the courts of Ireland;vii.

Annex I of the EU SCCs is deemed completed with the information set out in Exhibit A to this DPA, asapplicable; andviii.

Subject to Section 2.8 of this DPA, Annex II of the EU SCCs is deemed completed with the information
set out in Exhibit B to this DPA;

In relation to transfers of personal data protected by the EU GDPR and processed in accordance with
Section 2.2(b) of this DPA, the EU SCCs apply, completed as follows:i.

Module One will apply;ii.

in Clause 7, the optional docking clause will apply;iii.

in Clause 11, the optional language will not apply;iv.

in Clause 17, Option 1 will apply, and the EU SCCs will be governed by Irish law;v.

in Clause 18(b), disputes will be resolved before the courts of Ireland;vi.

Annex I of the EU SCCs is deemed completed with the information set out in Exhibit A to this DPA, asapplicable; andvii.

Subject to Section 2.8 of this DPA, Annex II of the EU SCCs is deemed completed with the information
set out in Exhibit B to this DPA;(c)

In relation to transfers of personal data protected by UK Data Protection Law, the EU SCCs: (i) apply ascompleted in accordance with paragraphs (a) and (b) above; and (ii) are deemed amended as specified by the
UK Addendum, which is deemed executed by the parties and incorporated into and forming an integral partof this DPA. In addition, Tables 1 to 3 in Part 1 of the UK Addendum is deemed completed respectively with
the information set out in Section 2.9, as well as Exhibits A and B of this DPA; Table 4 in Part 1 is deemedcompleted by selecting “neither party.” Any conflict between the terms of the EU SCCs and the UK Addendum
will be resolved in accordance with Section 10 and Section 11 of the UK Addendum.

(d)

In relation to transfers of personal data protected by the Swiss DPA, the EU SCCs will also apply in accordancewith paragraphs (a) and (b) above, with the following modifications:i.

any references in the EU SCCs to “Directive 95/46/EC” or “Regulation (EU) 2016/679” will be interpreted
as references to the Swiss DPA, and references to specific Articles of “Regulation (EU) 2016/679” will be
replaced with the equivalent article or section of the Swiss DPA;

ii.

references to “EU”, “Union”, “Member State” and “Member State law” will be interpreted as references
to Switzerland and Swiss law, as the case may be, and will not be interpreted in such a way as to exclude
data subjects in Switzerland from exercising their rights in their place of habitual residence inaccordance with Clause 18(c) of the EU SCCs;

iii.

Clause 13 of the EU SCCs and Part C of Annex 1 are modified to provide that the Federal Data Protection
and Information Commissioner (“FDPIC”) of Switzerland will have authority over data transfers3

governed by the Swiss DPA. Subject to the foregoing, all other requirements of Clause 13 will beobserved;
iv.

references to the “competent supervisory authority” and “competent courts” will be interpreted as
references to the FDPIC and competent courts in Switzerland;v.

in Clause 17, the EU SCCs will be governed by the laws of Switzerland; andvi.

Clause 18(b) states that disputes will be resolved before the applicable courts of Switzerland.

(e)

It is not the intention of either party to contradict or restrict any of the provisions set forth in the Standard
Contractual Clauses and, accordingly, if and to the extent the Standard Contractual Clauses conflict with any
provision of the Agreement (including this DPA), the Standard Contractual Clauses prevail to the extent ofsuch conflict;(f)

Although Atlassian does not rely on the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks (“Privacy Shield”)
as a legal basis for transfers of personal data in light of the judgment of the Court of Justice of the EU in Case
C-311/18, for so long as Atlassian US, Inc. and its covered entities are self-certified to the Privacy Shield
Atlassian will continue to process personal data in accordance with the Privacy Shield Principles. Atlassian willpromptly notify Customer if it makes a determination that Atlassian can no longer meet its obligations under
the Privacy Shield Principles; and(g)

If Atlassian adopts an alternative data export mechanism (including any new version of or successor to theStandard Contractual Clauses or Privacy Shield adopted pursuant to Applicable Data Protection Law) for thetransfer of personal data not described in this DPA (“Alternative Transfer Mechanism”), the Alternative
Transfer Mechanism will apply instead of any applicable transfer mechanism described in this DPA (but only
to the extent such Alternative Transfer Mechanism complies with Applicable Data Protection Law and extends
to the territories to which personal data is transferred).

2.7.

Confidentiality of processing: Atlassian must ensure that any person that it authorizes to process Customer
Personal Data (including Atlassian’s staff, agents and Sub-processors) will be subject to a duty of confidentiality(whether a contractual duty or a statutory duty), and must not permit any person to process Customer Personal
Data who is not under such a duty of confidentiality.

2.8.

Security: Atlassian and, to the extent required under the Agreement, Customer must implement appropriatetechnical and organizational measures in accordance with Applicable Data Protection Law (e.g., Art. 32 GDPR) to
protect Customer Personal Data from Security Incidents and to preserve the security and confidentiality of the
Customer Personal Data. Atlassian’s current technical and organizational measures are described in Exhibit B(“Security Measures”). Customer acknowledges that the Security Measures are subject to technical progress anddevelopment and that Atlassian may update or modify the Security Measures from time to time, provided that such
updates and modifications do not degrade or diminish the overall security of the Services.

2.9.

Sub-processing: Customer agrees that Atlassian may engage Sub-processors to process Customer Personal Data on
Customer’s behalf. The Sub-processors currently engaged by Atlassian and authorized by Customer are listed athttps://www.atlassian.com/legal/subprocessors. Atlassian will: (i) enter into a written agreement with each Subprocessor imposing data protection terms that require the Sub-processor to protect the Customer Personal Data to
the standard required by Applicable Data Protection Law (and in substance, to the same standard provided by thisDPA); and (ii) remain liable to Customer if such Sub-processor fails to fulfill its data protection obligations withregard to the relevant processing activities under Applicable Data Protection Law.

2.10.

Changes to Sub-processors: Atlassian must (i) make available an up-to-date list of the Sub-processors it has
appointed upon written request from Customer; and (ii) notify Customer if it adds any new Sub-processors at least
fourteen (14) days’ prior to allowing such Sub-processor to process Customer Personal Data. Customer must
subscribe to receive notice of updates to the list of Sub-processors, using the link in Section 2.9. Customer may
object in writing to Atlassian’s appointment of a new Sub-processor within five (5) calendar days of such notice,provided that such objection is based on reasonable grounds relating to data protection. In such an event, theparties will discuss such concerns in good faith with a view to achieving resolution. If the parties are not able toachieve resolution, Customer, as its sole and exclusive remedy, may terminate the Agreement (including this DPA)
for convenience.

2.11.

Cooperation obligations and data subjects’ rights:(a)Taking into account the nature of the processing, Atlassian must provide reasonable and timely assistance toCustomer (at Customer’s expense) to enable Customer to respond to: (i) any request from a data subject to4exercise any of its rights under Applicable Data Protection Law (including its rights of access, to rectification,
to erasure, to restriction, to objection, and data portability, as applicable); and (ii) any other correspondence,enquiry or complaint received from a data subject, regulator or other third party, in each case in respect ofCustomer Personal Data that Atlassian processes on Customer’s behalf;(b)

In the event that any request, correspondence, enquiry or complaint (referred to under paragraph (a) above)is made directly to Atlassian, Atlassian acting as a processor will not respond to such communication directly
without Customer’s prior authorization, unless legally required to do so, and instead, after being notified byAtlassian, Customer may respond. If Atlassian is legally required to respond to such a request, Atlassian willpromptly notify Customer and provide it with a copy of the request unless legally prohibited from doing so;
and

(c)

To the extent Atlassian is required under Applicable Data Protection Law, Atlassian will (at Customer’s request
and expense) provide reasonably requested information regarding the Services to enable the Customer tocarry out data protection impact assessments or prior consultations with data protection authorities, taking
into account the nature of processing and the information available to Atlassian.

2.12.

Security incidents: Upon becoming aware of a Security Incident, Atlassian will inform Customer without undue delay
and provide timely information (taking into account the nature of processing and the information available to
Atlassian) relating to the Security Incident as it becomes known or as is reasonably requested by Customer to allow
Customer to fulfill its data breach reporting obligations under Applicable Data Protection Law. Atlassian will further
take reasonable steps to contain, investigate, and mitigate the effects of the Security Incident. Atlassian’s
notification of or response to a Security Incident in accordance with this Section 2.12 will not be construed as an
acknowledgment by Atlassian of any fault or liability with respect to the Security Incident.

2.13.

Deletion or return of Data: Upon written request from Customer, Atlassian will delete or return to Customer all
Customer Personal Data (including copies) processed on behalf of the Customer in compliance with the procedures
and retention periods outlined in the DPA, Cloud Product Specific Terms or Trust Center; this requirement does not
apply to the extent Atlassian is required by applicable law to retain some or all of the Customer Personal Data, or
to Customer Personal Data it has archived on back-up systems, which Customer Personal Data Atlassian will securely
isolate and protect from any further processing, as further detailed in Exhibit A, Annex 1(B), Part A.

2.14.

Audit:(a)(b)

Customer acknowledges that Atlassian is regularly audited by independent third-party auditors and/orinternal
auditors
includingasmaybedescribed
from
time
to
time
at
https://www.atlassian.com/trust/compliance. Upon request, and on the condition that Customer has enteredinto an applicable non-disclosure agreement with Atlassian, Atlassian must:i.

supply (on a confidential basis) a summary copy of its audit report(s) (“Report”) to Customer, so
Customer can verify Atlassian’s compliance with the audit standards against which it has beenassessed, and this DPA; andii.

provide written responses (on a confidential basis) to all reasonable requests for information madeby Customer related to its Processing of Customer Personal Data, including responses to information
security and audit questionnaires, that are necessary to confirm Atlassian’s compliance with this DPA,
provided that Customer cannot exercise this right more than once per calendar year.

Only to the extent Customer cannot reasonably satisfy Atlassian’s compliance with this DPA through theexercise of its rights under Section 2.14(a) above, where required by Applicable Data Protection Law or theStandard Contractual Clauses, Customer and its authorized representatives may conduct audits (including
inspections) during the term of the Agreement to establish Atlassian’s compliance with the terms of this DPA,on the condition that Customer and its authorized representatives have entered into an applicable nondisclosure agreement with Atlassian. Notwithstanding the foregoing, any audit (or inspection) must be
conducted during Atlassian’s regular business hours, with reasonable advance notice (which may not be lessthan 45 calendar days) and subject to reasonable confidentiality procedures. Such audit (or inspection) may
not require Atlassian to disclose to Customer or its authorized representatives, or to allow Customer or its
authorized representatives to access:i.

any data or information of any other Atlassian customer (or such customer’s End Users);ii.

any Atlassian internal accounting or financial information;iii.

any Atlassian trade secret;

5

(c)

3.

iv.

any information that, in Atlassian’s reasonable opinion, could: (1) compromise the security ofAtlassian systems or premises; or (2) cause Atlassian to breach its obligations under Applicable Data
Protection Law or its security, confidentiality and or privacy obligations to any other Atlassiancustomer or any third party; orv.

any information that Customer or its authorized representatives seek to access for any reason otherthan the good faith fulfillment of Customer’s obligations under the Applicable Data Protection Law
and Atlassian’s compliance with the terms of this DPA.

An audit or inspection permitted in compliance with Section 2.14(b) will be limited to once per calendar year,
unless (1) Atlassian has experienced a Security Incident within the prior twelve (12) months which has
impacted Customer Personal Data; or (2) Customer is able to evidence an incidence of Atlassian’s material
noncompliance with this DPA.

2.15.

Law enforcement: If a law enforcement agency sends Atlassian a demand for Customer Personal Data (e.g., a
subpoena or court order), Atlassian will attempt to redirect the law enforcement agency to request that data
directly from Customer. As part of this effort, Atlassian may provide Customer’s contact information to the law
enforcement agency. If compelled to disclose Customer Personal Data to a law enforcement agency, then Atlassian
will give Customer reasonable notice of the demand to allow Customer to seek a protective order or otherappropriate remedy to the extent Atlassian is legally permitted to do so.

2.16.

Third party integrations and visibility. Through use of the Cloud Products and certain features thereof, as further
described in the Agreement and Documentation, Customer or Customer’s End Users, as applicable, may elect togrant third parties (for example, third party apps, or the Atlassian Community) visibility to data or content (which
may include Customer Personal Data). Customer understands that user profile information for the Cloud Products
may become publicly visible. Atlassian may make Customer’s data or content (which may include personal data)
visible to third parties consistent with this paragraph, as instructed by Customer or Customer’s End Users throughthe Cloud Products and relevant functionalities.

Relationship with the Agreement
3.1.

The parties agree that this DPA replaces and supersedes any existing DPA the parties may have previously enteredinto in connection with the Services.

3.2.

Except for the changes made by this DPA, the Agreement remains unchanged and in full force and effect. If there isany conflict between this DPA and the Agreement, this DPA will prevail to the extent of that conflict in connection
with the processing of Customer Personal Data. If there is any conflict between the Standard Contractual Clauses
and the Agreement (including this DPA), the Standard Contractual Clauses will prevail to the extent of that conflictin connection with the processing of Customer Personal Data governed under the Standard Contractual Clauses.

3.3.

Notwithstanding anything to the contrary in the Agreement or this DPA, the liability of each party and each party’s
affiliates under this DPA is subject to the exclusions and limitations of liability set out in the Agreement.

3.4.

Any claims against Atlassian or its affiliates under this DPA can only be brought by the Customer entity that is aparty to the Agreement against the Atlassian entity that is a party to the Agreement. In no event will this DPA or
any party restrict or limit the rights of any data subject or of any competent supervisory authority.

3.5.

This DPA will be governed by and construed in accordance with governing law and jurisdiction provisions in theAgreement, unless required otherwise by Applicable Data Protection Law.

3.6.

This DPA and the Standard Contractual Clauses will terminate simultaneously and automatically upon deletion by
Atlassian of the Customer Personal Data processed on behalf of the Customer, in accordance with Section 2.13 ofthis DPA.

6Customer Signatures

Customer name (Required): _________________________________
Address: _________________________________
Signature (Required): _________________________________Name (Required): _________________________________
Title (Optional): _________________________________CUSTOMER
Date (Required): _________________________________EU Representative (Required only where applicable): _________________________________
Contact details: _________________________________
Data Protection Officer (Required only where applicable): _________________________________
Contact details: _________________________________ATLASSIAN Signatures
Notwithstanding the signatures below of any other Atlassian Entity, an Atlassian Entity is not a party to this Addendum unlessthey are a party to the Agreement for the provision of the Cloud Products to the Customer. Where the Cloud Products areprovided under an Agreement with Atlassian Pty Ltd, Atlassian US, Inc. is also a party to this DPA.
Data Protection Point of Contact: Kelly Gertridge
Contact Details: dataprotection@atlassian.com

Atlassian PTY Ltd.

Signature: _________________________________
Name: Kelly Gertridge
Title: Head of Privacy
Date: 9/20/2022

Atlassian US, Inc.

Signature: _________________________________
Name: Kelly Gertridge
Title: Head of Privacy
Date: 9/20/2022

Trello Inc.

Signature: _________________________________
Name: Kelly Gertridge
Title: Head of Privacy
Date: 9/20/2022

Dogwood Labs, Inc.
(dba Statuspage.io)

Signature: _________________________________
Name: Kelly Gertridge
Title: Head of Privacy
Date: 9/20/2022

7

OpsGenie, Inc.

Signature: _________________________________
Name: Kelly Gertridge
Title: Head of Privacy
Date: 9/20/2022

Agile Craft LLC

Signature: _________________________________
Name: Kelly Gertridge
Title: Head of Privacy
Date: 9/20/2022

Halp Inc.

Signature: _________________________________
Name: Kelly Gertridge
Title: Head of Privacy
Date: 9/20/2022

8

EXHIBIT A
Description of the Processing Activities / Transfer
Annex 1(A) List of Parties:
Data Exporter

Data Importer

Name: Customer

Name: Atlassian

Address / Email Address: As provided for in the DPA

Address / Email Address: As provided for in the DPA

Contact Person's Name, position, and contact details: Asprovided for in the DPA

Contact Person's Name, position, and contact details: Asprovided for in the DPA

Activities relevant to the transfer: See Annex 1(B) below

Activities relevant to the transfer: See Annex 1(B) below

Role: See Annex 1(B)Role: See Annex 1(B)9Annex 1(B) Description of processing and transfer (as applicable)
The parties acknowledge that Atlassian's processing of personal data will include all personal data submitted or uploaded to theServices by Customer from time to time, for the purposes of, or otherwise in connection with, Atlassian providing the Services to
Customer.
Set out below are descriptions of the processing and transfers of personal data as contemplated as of the date of this DPA. Suchdescriptions are subject to change or may be supplemented pursuant to Section 2.3 of the DPA.
Part A: Description of processing and transfer (as applicable) for Modules 2 and 3 of the Standard Contractual Clauses(reference to Sections 2.2(a) as well as 2.6(a) DPA)
Atlassian cloud account profile (Identity)
Categories of data subjects

Customer, Customers' employees, Customers' collaborators, as well as all relevant End Users of theServices on behalf of the Customer.

Categories of personal datatransferredUser Account Information, for example:• Atlassian identifier associated with user account• About Me• Avatar Image and URL• Full name• Email address• Time zone
Employment Information, for example:• Job title / role
• Office / location• Company/organization

Sensitive data transferred?

None

Frequency of the transfer

Continuous

Nature of the processing

Providing the Services, including maintaining and displaying user profiles during collaboration,authentication of users, and managing access control as well as user permissions.

Purpose of the data transfer

Providing the Services, including allowing the collaboration and maintaining proper access controls anduser permissions.

Duration of processing

Data will be deleted 15 days (for evaluation sites) or 60 days (for paid subscription sites) after Customer
has been unsubscribed due to missed payment for an Atlassian product subscription or if Customer
cancels
their
Atlassianproduct
subscription.
For
more
informationsee
https://support.atlassian.com/security-and-access-policies/docs/track-storage-and-move-dataacross-products/

10

Jira Software Cloud, Confluence Cloud
Categories of data subjects

Customer, Customers' employees, Customers' collaborators, as well as all relevant End Users of theServices on behalf of the Customer.

Categories of personal datatransferredUser Account Information, for example:• Atlassian identifier associated with user account• About Me• Avatar Image and URL• Full name• Email address• Time zone
Employment Information, for example:• Job title / role
• Office / location• Company/organization
Personal data included in user generated content.

Sensitive data transferred?

None

Frequency of the transfer

Continuous

Nature of the processing

Providing the Services, including but not limited to the following features:• Import/export issues, pages and records• Track projects• Search content• Create and edit pages• Save and store files• Display profiles• Provide user alerts and messages

Purpose of the data transfer

Providing the Services, including but not limited to:• User and team communication• File sharing• Media management• Search• Content publishing• Third-party integration

Duration of processing

Upon termination, Customer accounts are deactivated within 15 days (for monthly subscriptions) and17 days (for annual subscriptions) after the end of the Customer’s current subscription period.
Atlassian retains data for deactivated products for 15 days (for evaluation licenses) or 60 days (for Free,
Standard, and Premium product plans) after the end of the Customer’s current subscription period.
Upon deletion, an archive of the data is kept for an additional 30 days.

11

Jira Service Management (JSM) / Jira Work Management (JWM)(Also see section for Ops Genie, which is integrated into JSM and JWM)
Categories of data subjects

Customer, Customers' employees, Customers' collaborators, as well as all relevant End Users of theServices on behalf of the Customer.

Categories of personal datatransferredUser Account Information, for example:• Atlassian identifier associated with user account• About Me• Avatar Image and URL• Full name• Email address• Time zone
Personal Identification, for example:• IP address• Language setting• Location/ Region/ City
• Phone numbers• Screen name/ Handle/ Nickname
Employment Information, for example:• Job title / role
• Office / location• Company/organization
Personal data included in user generated content

Sensitive data transferred?

None

Frequency of the transfer

Continuous

Nature of the processing

Providing the Services, including but not limited to following features:• Import/export issues and records• Tracking activity• Search content• Create / edit pages and content• Save and store files• Display profiles• Admin controls• Provide user alerts and messages

Purpose of the data transfer

Providing the Services, including but not limited to:• User and team communication• Account and login management• File sharing• Media management• Search• Content publishing• Third party integration

Duration of processing

Upon termination of service, Customer accounts are deactivated within 15 days (for monthly
subscriptions) and 17 days (for annual subscriptions) after the end of the Customer’s current subscription
period. Atlassian retains data for deactivated products for 15 days (for evaluation licenses) or 60 days
(for Free, Standard, and Premium product plans) after the end of the Customer’s current subscription
period. Upon deletion, an archive of the data is kept for an additional 30 days.

12

Bitbucket Cloud
Categories of data subjects

Customer, Customers' employees, Customers' collaborators, as well as all relevant End Users of theServices on behalf of the Customer.

Categories of personal datatransferredUser Account Information, for example:• Atlassian identifier associated with user account• About Me• Avatar Image and URL• Full name• Email address• Time zone
• Bitbucket ID
Personal Identification, for example:• IP address• Language setting• Location/ Region/ City
• Phone numbers• Screen name/ Handle/ Nickname
Employment Information, for example:• Job title / role
• Office / location• Company/Organization
Personal data included in user generated content

Sensitive data transferred?

None

Frequency of the transfer

Continuous

Nature of the processing

Providing the Services, including but not limited to following features:• Login/ Sign up• Display profiles• Export Repository / Source Code Repositories• Debugging• Import/Exports• Tracking Activity• Search Query/ Content• Create/edit pages• Save/ Store files• Admin controls / Password Management• Alerts/ Messages

Purpose of the data transfer

Providing the Services, including but not limited to:• User/Team Communication• File Sharing• Media Management• Search• Content Publishing• Account/ Login Management• Third party integration

Duration of processing

On termination of a Bitbucket Cloud account, and at the request of the Customer, customer data will
be removed from the live production database. The team’s data will remain in encrypted Bitbucket
Cloud database backups until those backups fall out of the 35-day backup retention window and aredestroyed in accordance with Bitbucket Cloud’s data retention policy.
In the event a database restore is necessary within 35 days of a requested data deletion, theBitbucket Cloud operations team will re-delete the data as soon as reasonably possible after the live
production system is fully restored.

13

Trello
Categories of data subjects

Customer, Customers’ employees, Customers’ collaborators, as well as all relevant End Users of theServices on behalf of the Customer.’’

Categories of personal datatransferredUser Account Information, for example:• Atlassian identifier associated with user account• About Me• Avatar Image and URL• Full Name
• Email address• Time zone
Personal Identification, for example:• IP address• Cookie information• Language setting• Location/ Region/ City
• Phone numbers• Screen name/ Handle/ Nickname
Employment Information, for example:• Job title / role
• Office / location• Company/organization
Personal data included in user generated content

Sensitive data transferred?

None

Frequency of the transfer

Continuous

Nature of the processing

Providing the Services, including but not limited to following features:• Import/export cards and records• Tracking Activity• Search Query/ Content• Create/edit pages & content• Save/ Store files• Display profiles• Admin controls• Alerts

Purpose of the data transfer

Providing the Services, including but not limited to:• User/Team Communication• File Sharing• Media Management• Search• Content Publishing• Account/ Login Management• 3rd Party Integration

Duration of processing

On termination of a Trello enterprise contract, and at the request of the Customer, the data belonging
to the enterprise teams will be completely removed from the live production database and all fileattachments uploaded directly to Trello will be removed within 30 days. The team’s data will remain in
encrypted Trello database backups until those backups fall out of the 90-day backup retention window
and are destroyed in accordance with Trello’s data retention policy.
In the event a database restore is necessary within 90 days of a requested data deletion, the Trello
operations team will re-delete the data as soon as reasonably possible after the live production system
is fully restored.

14

Opsgenie
Categories of data subjects

Customer, Customers' employees, Customers' collaborators, as well as all relevant End Users of theServices on behalf of the Customer.

Categories of personal datatransferredUser Account Information, for example:• Atlassian identifier associated with user account• About Me• Avatar Image and URL• Full Name
• Email address• Time zone
Personal Identification, for example:• IP address• Cookie information• Language setting• Location/ Region/ City
• Phone numbers• Screen name/ Handle/ Nickname
Employment Information, for example:• Job title / role
• Office / location• Company/organization
Personal data included in user generated content

Sensitive data transferred?

None

Frequency of the transfer

Continuous

Nature of the processing

Providing Services, including but not limited to the following features:• Import/export records• Tracking Activity• Search Query/ Content• Create/edit pages & content• Save/ Store files• Display profiles• Admin controls• Alerts

Purpose of the data transfer

Providing Services, including but not limited to:• User/Team Communication• Account/ Login Management• Third Party Integration

Duration of processing

When a configuration item, user, or alert, incident is deleted from Opsgenie, the entity and child data
will be deleted by Opsgenie.
When a user is deleted from Opsgenie, Audit Logs (Alert Log - Incident Timeline) will still have audit
records like "Email notification sent to x@y.com", this is important as part of Incident audit. Customers
can delete Alerts & Incident, Alert logs & Incident Timeline will be deleted.
Customer Logs visible on the Logs page are immutable, and have a retention of 1 year.
Customers can delete data from web applications manually or automatically by using Opsgenie rest api.
When paid subscription ends, Customers may contact Atlassian Customer Support so that all data ofCustomers can be deleted.
Legal & Security Auditing reasons: Customer Logs, Data Backup & System Log Archives will be stored as
an archive for 1 year, regardless of whether Customer data is fully deleted or not. Archives can not be
accessed directly by Customers, access is restricted to Opsgenie authorized employees.

15Statuspage
Categories of data subjects

Customer, Customers' employees, Customers' collaborators, as well as all relevant End Users of theServices on behalf of the Customer.

Categories of personal datatransferredUser Account Information, for example:• Atlassian identifier associated with user account• About Me• Avatar Image and URL• Full name• Email address• Time zone
• Phone number• Company/Organization
Personal data included in user generated content
Browsing information within Admin settings

Sensitive data transferred?

None

Frequency of the transfer

Continuous

Nature of the processing

Providing Services, including but not limited to following features:• Login/ Sign up• Import/export records• Tracking Activity• Search Query/ Content• Create/edit content (incident communication)• Save/ Store files• Display profiles• Admin controls• Notifications

Purpose of the data transfer

Providing Services, including but not limited to:• Incident communication• Scheduled maintenances• Content Publishing• Account/ Login Management• Third party integration

Duration of processing

On termination of a Statuspage account, and at the request of the Customer, customer data will be
removed from the live production database. The customer data will remain in encrypted Statuspage
database backups until those backups fall out of the 30-day backup retention window and are destroyedin accordance with Atlassian's data retention policy.
In the event that a database restore is necessary within 30 days of a requested data deletion, theStatuspage operations team will re-delete the data as soon as reasonably possible after the live
production system is fully restored.

16

Jira Align
Categories of data subjects

Customer, Customers' employees, Customers' collaborators, as well as all relevant End Users of theServices on behalf of the Customer.

Categories of personal datatransferredUser Account Information, for example:• Jira Align ID• Avatar Image and URL• Full name• Email address• Time zone
Personal Identification, for example:• Screen name/ Handle/ Nickname• Language setting• Location/ Region/ City
Employment Information, for example:• Job Title/ Role
Browsing information on Admin settings
Personal data included in user generated content

Sensitive data transferred?

None

Frequency of the transfer

Continuous

Nature of the processing

Providing Services, including but not limited to following features:• Import/export records• Tracking Activity• Search Query/ Content• Create/edit pages• Save/ Store files• Display profiles• Admin controls• Alerts/ Messages• Data Warehouse Sync
• Provide Business intelligence for Customer

Purpose of the data transfer

Providing Services, including but not limited to:• User/Team Communication• File Sharing• File Storage• Media Management• Search• Content Publishing• Account/ Login Management• Business Intelligence feature• Third party integration

Duration of processing

On termination of a Jira Align Enterprise contract, and at the request of the Customer, the database will
be dropped from the live production database. This will be done within the support team service levelagreement. The customer data will remain in encrypted Jira Align database backups until those backups
fall out of the 35-day backup retention window and are destroyed in accordance with Atlassian's dataretention policy.
In the event a database restore is necessary within 35 days of a requested data deletion, the Jira Alignoperations team will re-delete the data as soon as reasonably possible after the live production system
is fully restored.

17

Halp
Categories of data subjects

Customer, Customers' employees, Customers' collaborators, as well as all relevant End Users of theServices on behalf of the Customer.

Categories of personal datatransferredUser Account Information, for example:• User ID• Avatar Image and URL• Full name• Email address• Time zone
Personal Identification, for example:• Screen name/ Handle/ Nickname• Phone number• IP address
Employment Information, for example:• Job Title/ Role
• Halp role
• Zendesk User ID*• Zendesk User Role*
Browsing information on Admin settings
Personal data included in user generated content*only if customers integrate with Zendesk

Sensitive data transferred?

None

Frequency of the transfer

Continuous

Nature of the processing

Providing Services, including but not limited to following features:• Use email addresses to map identities• Display user profiles• Logging in/Authentication• Create & update tickets• Sync data between different platforms (e.g., Sync data primarily from Jira/ Zendesk/ MS Teams)• Create tickets from email/ web client/ Slack• Provide user alerts and messages

Purpose of the data transfer

Providing Services, including but not limited to:• User/Team Communication• File Sharing• Content Management• Account/ Login Management• Third party integration

Duration of processing

At the request of the Customer, the data belonging to the Customer will be completely removed fromthe live production database and all file attachments uploaded directly to Halp will be removed within
30 days. The team’s data will remain in encrypted Halp database backups until those backups fall out of
the 90-day backup retention window and are destroyed in accordance with Halp’s data retention
policy. In the event that a database restore is necessary within 90 days of a requested data deletion,
the Halp operations team will re-delete the data as soon as reasonably possible after the live
production system is fully restored.
In the event that a database restore is necessary within 35 days of a requested data deletion, Halp’s
operations team will re-delete the data as soon as reasonably possible after the live production system
is fully restored.

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Part B: Description of processing and transfer (as applicable) for Module 1 of the Standard Contractual Clauses (reference toSections 2.2(b) as well as 2.6(b) DPA)All Cloud Products: Atlassian as a controller
Categories of data subjects

Customer, Customers' employees, Customers' collaborators, as well as all relevant End Users of theServices on behalf of the Customer.
Personal data relating to or obtained in connection with the operation, support or use of theServices, e.g.:
User Account Information, for example pseudonymous Atlassian IDs, Cloud IDs, Site IDs,Tenant ID,
Segment Anonymous IDs
Payment and billing information, to the extent it includes personal data
Device and connection information, for example:

Categories of personal datatransferred•

IP address•

Cookie information•

Device information•

Browser information

Information on the use of the Services, for example:•

Event Name (i.e., what action the user performed)•

Event Timestamp•

Page URL•

Referring URL

Support data*
Personal data provided through various Atlasian support channels, including for example Atlassian ID,
SEN (Support Entitlement Number), username, contact information and any personal data contained
within a summary of the problem experienced or information needed to resolve the support case.
* If any user generated content is submitted via support tickets, Atlassian acts as a processor of such
personal data and Sections 2.2(a)as well as 2.6(a) DPA apply accordingly.
Sensitive data transferred?

None

Frequency of the transfer

Continuous

Nature of the processing

Collection, storage, and processing of relevant personal data for the purposes identified in this Part B.

Purpose of the data transfer

Personal data will be processed for Atlassian’s legitimate business purposes. This entails in particular
the following:• To facilitate security, fraud prevention, performance monitoring, business continuity and disasterrecovery in order to protect Customers, End Users and Atlassian.
• To engage and to provide support and assistance to Customer and End Users as requested fromtime to time.
• To comply with legal and financial reporting obligations• To administer the Services, including to calculate usage-based billing• To derive insights in order to maintain, develop, and improve the Services and support, including
for research and development purposes• To derive insights in order to inform internal business analysis and product strategy.

Duration of processing

Atlassian may process personal data for the purposes described above for the duration of the DPA, andfor as long as Atlassian has a legitimate need to retain the personal data for the purposes it wascollected or transferred, in accordance with Applicable Data Protection Law.

19

Annex 1(C): Competent supervisory authority
The data exporter’s competent supervisory authority will be determined in accordance with the GDPR.

20

EXHIBIT B
Technical and Organizational Security Measures
1.

Purpose.
This Exhibit describes Atlassian’s security program, security certifications, and physical, technical, organizational andadministrative controls and measures to protect Customer Data from unauthorized access, destruction, use, modification
or disclosure (the “Security Measures“). The Security Measures are intended to be in line with the commonly-accepted
standards of similarly-situated software-as-a-service providers (“industry standard“). Unless otherwise specified in theapplicable Product-Specific Terms, the Security Measures apply to all Atlassian Cloud Products (other than No-Charge
Products or Free and Beta Products) that are available under the Agreement.

2.

Updates and Modifications.
The Security Measures are subject to technical progress and development and Atlassian may update or modify the Security
Measures from time to time, provided that such updates and modifications do not materially degrade or diminish theoverall security of the Cloud Products, as described in this document.

3.

Definitions.
Any capitalized terms used but not defined in this document have the meanings set out in the Agreement. The term
“Customer Data“ means any data, content or materials provided to Atlassian by or at the direction of Customer or its End
Users via the Cloud Products, including from Third-Party Products.

4.

Security Measures.
The Security Measures are described in the following table:
MeasureDescription
Data Encryption

Measures of pseudonymisationand encryption of personal data

Atlassian has and will maintain: (i) an established method to encrypt Customer Data in transit andat rest; (ii) an established method to securely store passwords following industry standard practices;and (iii) use established key management methods.
Any Customer Data is encrypted in transit over public networks using TLS 1.2 or greater, with Perfect
Forward Secrecy (PFS) to protect it from unauthorized disclosure or modification.
Data drives on servers holding Customer Data and attachments use full disk, industry-standard, AES256 encryption at rest.
Security Program
Atlassian will maintain a security management program that includes but is not limited to:

Measures for ensuring ongoing
confidentiality, integrity,
availability and resilience ofprocessing systems and servicesa)executive review, support and accountability for all security related policies and practices;b)a written information security policy and framework that meets or exceeds industry standards
and that, as a baseline, includes (i) defined information security roles and responsibilities, (ii)a formal and effective risk mitigation program and (iii) a service provider security
management program;c)

periodic risk assessments of all Atlassian owned or leased systems processing Customer Data;d)prompt review of security incidents affecting the security of Atlassian systems processing
Customer Data, including determination of root cause and corrective action;e)a formal controls framework based on, among other things, formal audit standards such as
the AICPA SOC 2 Type II report, ISO27001, and NIST 800-53 (or any successor standard);

f)

processes to document non-compliance with the security measures;g)

processes to identify and quantify security risks, develop mitigation plans, which must be
approved by Atlassian’s Chief Trust Officer (or one of their delegates), and track theimplementation of such plans; andh)a comprehensive security testing methodology that consists of diverse and independent
approaches that, when combined, are reasonably designed to maximize coverage for a variedand diverse set of attack vectors.

Atlassian will periodically (and, in any event, no less frequently than annually) review, test and,
where applicable, update such security management program.
Security Incident Notification

21

Measure

Description
Atlassian will notify Customer of Security Incidents in accordance with the Atlassian Data Processing
Addendum.
Employee Screening, Training, Access and Controls
Atlassian will maintain policies and practices that include the following controls and safeguards
applied to Atlassian staff who have access to Customer Data and/or provide Support and Services
to Customer:a)pre-hire background checks (including criminal record inquiries) on Atlassian job candidates,
which are conducted by a third-party background check provider and in accordance withapplicable Laws and generally accepted industry standards;b)periodic security awareness training;c)a disciplinary policy and process to be used when Atlassian staff violate Atlassian’s security
policies;d)access to Atlassian IT systems only from approved Atlassian-managed devices withappropriate technical security controls (including two-factor authentication);e)controls designed to limit access to Customer Data to only those Atlassian staff with an actual
need-to-know such Customer Data. Such controls include the use of a formal accessmanagement process for the request, review, approval and provisioning for all Atlassian staff
with access to Customer Data; andf)separation of duties to prevent a single Atlassian employee from controlling all key aspects ofa critical transaction or business process related to Customer Data or systems.

Other matters
See the items below titled “Measures for ensuring the ability to restore the availability and accessto personal data in a timely manner in the event of a physical or technical incident,“ and “Measures
for the protection of data during storage“.
Resilience Program
During the Subscription Term, Atlassian’s business continuity and disaster recovery plans(collectively, the “BCDR Plans“) will address at least the following topics:

Measures for ensuring theability to restore the availability
and access to personal data in atimely manner in the event of aphysical or technical incidenta)the availability of human resources with appropriate skill sets;b)

the availability of all IT infrastructure, telecommunications capabilities and any othertechnology used or relied upon by Atlassian in the provision of the Products;c)

Atlassian’s plans for storage and continuity of use of data and software;d)clear recovery time objectives (RTOs) and recovery point objectives (RPOs);e)mechanisms for the geographic diversity or back-up of business operations;f)the potential impact of cyber events and Atlassian’s ability to maintain business continuity inlight of such events, as well as a framework and procedure to respond to and remediate such
events;g)

the management of data corruption incidents; andh)procedures and frequency of testing of the BCDR Plans.

Atlassian will periodically (and, in any event, no less frequently than annually) review, test and,
where applicable, update the BCDR Plans.
Compliance Program

Processes for regularly testing,assessing and evaluating theeffectiveness of technical andorganisational measures inorder to ensure the security ofthe processing

Atlassian will maintain a compliance program that includes independent third-party audits andcertifications. Atlassian will make available to Customer, via the Atlassian Compliance Site, copiesof the most up-to-date version of the following third-party certifications or reports in relation to the
Cloud Products: (i) a SOC2 Type II report; (ii) an International Organization for Standardization (ISO)27001 certificate (which includes adherence to ISO 27002 and 27018 standards) and, upon written
request, the relevant Statement of Applicability; or (iii) any successor of any of the foregoing.
All such reports or certificates will be made available on the Atlassian Compliance Site, and will bemade available within a commercially reasonable time of the relevant audit and/or certification
process being completed.
Vulnerability Management
Atlassian will maintain the following vulnerability management processes:
Vulnerability Scanning and Remediation. Atlassian employs processes and tools in line with industry
standards to conduct frequent vulnerability scanning to test Atlassian’s network and infrastructure
and application vulnerability testing to test Atlassian applications and services. Atlassian applies

22Measure

Description
security patches to software components in production and development environments as soon ascommercially practicable in accordance with our Security Bug Fix Policy.
Identifying Malicious Threats. Atlassian employs processes and tools in line with industry standards
to identify malicious actors and prevent them from accessing Customer Data or Atlassian systems
that process Customer Data. These include, but are not limited to, maintaining software that
attempts to identify and detect attempted intrusions, behaviors consistent with Internet-based
attacks, and indicators of potential compromise. Atlassian will maintain a security incident andevent management system and supporting processes to notify appropriate personnel in responseto threats.
Vulnerability Testing.

Measures for user identification
and authorisation

Measures for the protection ofdata during transmissiona)

Atlassian conducts internal vulnerability testing, as described here. This includes our bug
bounty program. We make the results of these internal tests publicly available and commit
to making bug fixes in line with our Security Bug Fix Policy.

b)

Customer may, either itself or through an independent third party (who has entered into
confidentiality obligations with Atlassian), perform its own vulnerability testing of its Cloud
Products in accordance with the Security Test Rules. Customer may report any vulnerabilities
impacting the Cloud Products to Atlassian in accordance with the procedures set forth in the
Security Test Rules.

c)

Atlassian will use commercially reasonable efforts to address identified security
vulnerabilities in our Cloud Products and our infrastructure in accordance with the Security
Bug Fix Policy. The parties acknowledge that Atlassian may update the Security Bug Fix Policy
from time to time in its discretion, provided such updates do not result in a material
derogation of the Security Bug Fix Policy.

Atlassian cloud users can authenticate using username and password, or external IdPs (incl. via
SAML, Google, Microsoft and Apple). All credentials are hosted in the application database, whichis encrypted at rest. Passwords are stored using a secure hash + salt algorithm.
Administrators are able to configure and enforce password complexity requirements for managed
accounts
via
AtlassianAccess: https://support.atlassian.com/security-and-accesspolicies/docs/manage-your-password-policy/. Administrators are also able to enforce SSO via
Atlassian Access.
See the item above titled “Measures of pseudonymisation and encryption of personal data“
Data Hosting Facilities
Atlassian will, no less frequently than annually, request assurances (e.g., in the form of an
independent third party audit report and vendor security evaluations) from its data hosting
providers that store or process Customer Data that:

Measures for the protection ofdata during storagea)such data hosting provider’s facilities are secured in an access-controlled location andprotected from unauthorized access, damage, and interference;b)such data hosting provider’s facilities employ physical security appropriate to theclassification of the assets and information being managed; andc)such data hosting provider’s facilities limit and screen all entrants employing measures suchas on-site security guard(s), badge reader(s), electronic lock(s), or a monitored closed caption
television (CCTV).

Tenant Separation
Atlassian will use established measures to ensure that Customer Data is kept logically segregatedfrom other customers' data when at-rest.
Data Encryption
See the item above titled “Measures of pseudonymisation and encryption of personal data“
Measures for ensuring physicalsecurity of locations at which
personal data are processed

See the item above titled “Measures for the protection of data during storage“.

Measures for ensuring events
logging

Audit logging is available via API. See: https://support.atlassian.com/security-and-accesspolicies/docs/track-organization-activities-from-the-audit-log/

Measures for ensuring system
configuration, including default
configuration

See the item above titled “Measures for ensuring ongoing confidentiality, integrity, availability andresilience of processing systems and services“.

23Measure

Description

Measures for internal IT and IT
security governance andmanagement

See the item above titled “Measures for ensuring ongoing confidentiality, integrity, availability andresilience of processing systems and services“.

Measures forcertification/assurance ofprocesses and products

See the item above titled “Processes for regularly testing, assessing and evaluating the effectivenessof technical and organisational measures in order to ensure the security of the processing“.

Measures for ensuring data
minimisation

See “What information we collect about you” section of the Atlassian Privacy Policy.

Measures for ensuring data
quality

See the items above titled “Measures of pseudonymisation and encryption of personal data“,“Measures for ensuring ongoing confidentiality, integrity, availability and resilience of processing
systems and services“, and “Measures for the protection of data during storage“.
In addition, Customer and its Users have the ability to update any Customer Data provided toAtlassian using in-built product functionality, as further described in the Documentation.
Data Retention and Destruction Standard
Atlassian maintains a Data Retention and Destruction Standard, which designates how long we needto maintain data of different types. The Data Retention and Destruction Standard is guided by thefollowing principles:

Measures for ensuring limited
data retention

Measures for ensuringaccountability●●

Records should be maintained as long as they serve a business purpose.

●

Records that no longer serve a business purpose, and for which Atlassian has no duty toretain, should be disposed. Copies or duplicates of such data should also be disposed. To theextent Atlassian has a duty to retain a specified number of copies of a Record, such numberof copies should be retained.

●

Atlassian’s practices implementing this Standard may vary across departments, systems andmedia, and will of necessity evolve over time. These practices will be reviewed under ourcompany-wide policy review practices.

Records that serve a business purpose, or which Atlassian has a legal, regulatory, contractualor other duty to retain, will be retained.

See the item above titled “Processes for regularly testing, assessing and evaluating the effectivenessof technical and organisational measures in order to ensure the security of the processing“.
Data Export
Atlassian allows Customer to export its Customer Data from the Cloud Products as described in theDocumentation.
Secure Deletion

Measures for allowing data
portability and ensuring erasure

Atlassian will maintain a process reasonably designed to ensure secure destruction and deletion of
any and all Customer Data as provided in the Agreement. Such Customer Data will be securely
destroyed and deleted by Atlassian so that: (a) Customer Data cannot be practicably read orreconstructed, and (b) the Atlassian systems that store Customer Data are securely erased and/or
decommissioned disks are destroyed.
Privacy Rights
See:

●
●

“Managing Individual privacy rights” on our Manage your business’ data privacy page; and“Privacy requests” on https://www.atlassian.com/hu/trust/privacy/personal-data-privacy.

24