Insofar as we are processing personal data on your behalf and under your instruction as part of providing services to you, we shall be considered data processor in accordance with the definition set out in Article 4(8) of the GDPR. 3.1.1 When we are providing services to you by which we process personal data, we must comply with the requirements set out in Article 28 of the GDPR in our capacity as data processor. These requirements are set out as part of these Terms and Conditions in Schedule A (Data Processing Terms). 3.2 Insofar as we are processing personal data for our own purpose and using means independently determined by us, we are a data controller. This is the case for the categories of data subjects and types of personal data which are listed in Attachment 1 to Schedule A (Data Processing Terms), when the personal data is processed for the purpose of using and storing the personal data in an IT system owned by Klar Reward Agency, to be used for analysis, surveys and benchmarking of salary data across markets and industries. 3.2.1 Personal data processed in an IT system owned by Klar Reward Agency will be stored for a period of up to three (3) years for the purpose of data analysis and data validation of current and future surveys/analysis/benchmarks, after which the data is deleted from the IT system. 3.2.2 Notice to data subjects. 3.2.2.1 The obligation on us as data controller to provide notification to data subjects, as set out in Article 14 of the GDPR, is allocated to the customer to ensure that data subjects, being company employees are duly informed that their information will be used for statistical purposes by Klar Reward Agency as part of providing services to the customer. As such we rely on the customer’s notice and it is therefore the responsibility of the customer to ensure that data subjects are notified in accordance with Article 14 of the GDPR.  3.2.3 Use of personal data in an IT system. 3.2.3.1 By agreeing to these Terms and Conditions, you allow Klar Reward Agency to use and store the raw data provided by you in an IT system hosted on a local server on the premises of where Klar Reward Agency conducts its business.