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Data protection

Data Processing Agreement (DPA / AVV)

LicenseMeter processes directory and license metadata on your behalf, so a data processing agreement under Art. 28 GDPR comes with every workspace. It is the European Commission's standard contractual clauses, unchanged, with our annexes. The full text is below; download the pre-signed PDF in English or German for your records and procurement checklist.

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Download PDFVersion 2.1 · Effective 19 September 2026

How to put this agreement in place

  1. 1.Every workspace accepts it online: an owner or admin accepts the current version once in the LicenseMeter portal, and the acceptance is recorded.
  2. 2.On Pro and MSP an owner can also sign it with the company named as a party, and download the PDF signed by both sides.
  3. 3.LicenseMeter signs its own agreement. Customer templates are not negotiated on Pro.

About this agreement

This agreement is made of the standard contractual clauses between controllers and processors that the European Commission adopted under Article 28(7) GDPR with Implementing Decision (EU) 2021/915 of 4 June 2021. The Clauses are reproduced below without any change. Where the Clauses ask the parties to choose, the choice is: Regulation (EU) 2016/679 applies; the optional docking clause (Clause 5) is included; sub-processors are engaged under a general written authorisation with a notice period of 30 days (Clause 7.7(a), option 2).

Only Annexes I to IV are written by LicenseMeter. The customer accepts the agreement online in the LicenseMeter portal. It applies to the use of the LicenseMeter service under the LicenseMeter Terms and Conditions.

Standard contractual clauses

SECTION I

Clause 1: Purpose and scope

  1. (a)

    The purpose of these Standard Contractual Clauses (the Clauses) is to ensure compliance with Article 28(3) and (4) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

  2. (b)

    The controllers and processors listed in Annex I have agreed to these Clauses in order to ensure compliance with Article 28(3) and (4) of Regulation (EU) 2016/679 and/or Article 29(3) and (4) of Regulation (EU) 2018/1725.

  3. (c)

    These Clauses apply to the processing of personal data as specified in Annex II.

  4. (d)

    Annexes I to IV are an integral part of the Clauses.

  5. (e)

    These Clauses are without prejudice to obligations to which the controller is subject by virtue of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

  6. (f)

    These Clauses do not by themselves ensure compliance with obligations related to international transfers in accordance with Chapter V of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

Clause 2: Invariability of the Clauses

  1. (a)

    The Parties undertake not to modify the Clauses, except for adding information to the Annexes or updating information in them.

  2. (b)

    This does not prevent the Parties from including the standard contractual clauses laid down in these Clauses in a broader contract, or from adding other clauses or additional safeguards provided that they do not directly or indirectly contradict the Clauses or detract from the fundamental rights or freedoms of data subjects.

Clause 3: Interpretation

  1. (a)

    Where these Clauses use the terms defined in Regulation (EU) 2016/679 or Regulation (EU) 2018/1725 respectively, those terms shall have the same meaning as in that Regulation.

  2. (b)

    These Clauses shall be read and interpreted in the light of the provisions of Regulation (EU) 2016/679 or Regulation (EU) 2018/1725 respectively.

  3. (c)

    These Clauses shall not be interpreted in a way that runs counter to the rights and obligations provided for in Regulation (EU) 2016/679 / Regulation (EU) 2018/1725 or in a way that prejudices the fundamental rights or freedoms of the data subjects.

Clause 4: Hierarchy

In the event of a contradiction between these Clauses and the provisions of related agreements between the Parties existing at the time when these Clauses are agreed or entered into thereafter, these Clauses shall prevail.

Clause 5 - Optional: Docking clause

  1. (a)

    Any entity that is not a Party to these Clauses may, with the agreement of all the Parties, accede to these Clauses at any time as a controller or a processor by completing the Annexes and signing Annex I.

  2. (b)

    Once the Annexes in (a) are completed and signed, the acceding entity shall be treated as a Party to these Clauses and have the rights and obligations of a controller or a processor, in accordance with its designation in Annex I.

  3. (c)

    The acceding entity shall have no rights or obligations resulting from these Clauses from the period prior to becoming a Party.

SECTION II: OBLIGATIONS OF THE PARTIES

Clause 6: Description of processing(s)

The details of the processing operations, in particular the categories of personal data and the purposes of processing for which the personal data is processed on behalf of the controller, are specified in Annex II.

Clause 7: Obligations of the Parties

7.1. Instructions
  1. (a)

    The processor shall process personal data only on documented instructions from the controller, unless required to do so by Union or Member State law to which the processor is subject. In this case, the processor shall inform the controller of that legal requirement before processing, unless the law prohibits this on important grounds of public interest. Subsequent instructions may also be given by the controller throughout the duration of the processing of personal data. These instructions shall always be documented.

  2. (b)

    The processor shall immediately inform the controller if, in the processor’s opinion, instructions given by the controller infringe Regulation (EU) 2016/679 / Regulation (EU) 2018/1725 or the applicable Union or Member State data protection provisions.

7.2. Purpose limitation

The processor shall process the personal data only for the specific purpose(s) of the processing, as set out in Annex II, unless it receives further instructions from the controller.

7.3. Duration of the processing of personal data

Processing by the processor shall only take place for the duration specified in Annex II.

7.4. Security of processing
  1. (a)

    The processor shall at least implement the technical and organisational measures specified in Annex III to ensure the security of the personal data. This includes protecting the data against a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access to the data (personal data breach). In assessing the appropriate level of security, the Parties shall take due account of the state of the art, the costs of implementation, the nature, scope, context and purposes of processing and the risks involved for the data subjects.

  2. (b)

    The processor shall grant access to the personal data undergoing processing to members of its personnel only to the extent strictly necessary for implementing, managing and monitoring of the contract. The processor shall ensure that persons authorised to process the personal data received have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality.

7.5. Sensitive data

If the processing involves personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data or biometric data for the purpose of uniquely identifying a natural person, data concerning health or a person’s sex life or sexual orientation, or data relating to criminal convictions and offences (“sensitive data”), the processor shall apply specific restrictions and/or additional safeguards.

7.6. Documentation and compliance
  1. (a)

    The Parties shall be able to demonstrate compliance with these Clauses.

  2. (b)

    The processor shall deal promptly and adequately with inquiries from the controller about the processing of data in accordance with these Clauses.

  3. (c)

    The processor shall make available to the controller all information necessary to demonstrate compliance with the obligations that are set out in these Clauses and stem directly from Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725. At the controller’s request, the processor shall also permit and contribute to audits of the processing activities covered by these Clauses, at reasonable intervals or if there are indications of non-compliance. In deciding on a review or an audit, the controller may take into account relevant certifications held by the processor.

  4. (d)

    The controller may choose to conduct the audit by itself or mandate an independent auditor. Audits may also include inspections at the premises or physical facilities of the processor and shall, where appropriate, be carried out with reasonable notice.

  5. (e)

    The Parties shall make the information referred to in this Clause, including the results of any audits, available to the competent supervisory authority/ies on request.

7.7. Use of sub-processors
  1. (a)

    The processor has the controller’s general authorisation for the engagement of sub-processors from an agreed list. The processor shall specifically inform in writing the controller of any intended changes of that list through the addition or replacement of sub-processors at least 30 days in advance, thereby giving the controller sufficient time to be able to object to such changes prior to the engagement of the concerned sub-processor(s). The processor shall provide the controller with the information necessary to enable the controller to exercise the right to object.

  2. (b)

    Where the processor engages a sub-processor for carrying out specific processing activities (on behalf of the controller), it shall do so by way of a contract which imposes on the sub-processor, in substance, the same data protection obligations as the ones imposed on the data processor in accordance with these Clauses. The processor shall ensure that the sub-processor complies with the obligations to which the processor is subject pursuant to these Clauses and to Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

  3. (c)

    At the controller’s request, the processor shall provide a copy of such a sub-processor agreement and any subsequent amendments to the controller. To the extent necessary to protect business secret or other confidential information, including personal data, the processor may redact the text of the agreement prior to sharing the copy.

  4. (d)

    The processor shall remain fully responsible to the controller for the performance of the sub-processor’s obligations in accordance with its contract with the processor. The processor shall notify the controller of any failure by the sub-processor to fulfil its contractual obligations.

  5. (e)

    The processor shall agree a third party beneficiary clause with the sub-processor whereby - in the event the processor has factually disappeared, ceased to exist in law or has become insolvent - the controller shall have the right to terminate the sub-processor contract and to instruct the sub-processor to erase or return the personal data.

7.8. International transfers
  1. (a)

    Any transfer of data to a third country or an international organisation by the processor shall be done only on the basis of documented instructions from the controller or in order to fulfil a specific requirement under Union or Member State law to which the processor is subject and shall take place in compliance with Chapter V of Regulation (EU) 2016/679 or Regulation (EU) 2018/1725.

  2. (b)

    The controller agrees that where the processor engages a sub-processor in accordance with Clause 7.7. for carrying out specific processing activities (on behalf of the controller) and those processing activities involve a transfer of personal data within the meaning of Chapter V of Regulation (EU) 2016/679, the processor and the sub-processor can ensure compliance with Chapter V of Regulation (EU) 2016/679 by using standard contractual clauses adopted by the Commission in accordance with of Article 46(2) of Regulation (EU) 2016/679, provided the conditions for the use of those standard contractual clauses are met.

Clause 8: Assistance to the controller

  1. (a)

    The processor shall promptly notify the controller of any request it has received from the data subject. It shall not respond to the request itself, unless authorised to do so by the controller.

  2. (b)

    The processor shall assist the controller in fulfilling its obligations to respond to data subjects’ requests to exercise their rights, taking into account the nature of the processing. In fulfilling its obligations in accordance with (a) and (b), the processor shall comply with the controller’s instructions

  3. (c)

    In addition to the processor’s obligation to assist the controller pursuant to Clause 8(b), the processor shall furthermore assist the controller in ensuring compliance with the following obligations, taking into account the nature of the data processing and the information available to the processor:

    1. (1)

      the obligation to carry out an assessment of the impact of the envisaged processing operations on the protection of personal data (a ‘data protection impact assessment’) where a type of processing is likely to result in a high risk to the rights and freedoms of natural persons;

    2. (2)

      the obligation to consult the competent supervisory authority/ies prior to processing where a data protection impact assessment indicates that the processing would result in a high risk in the absence of measures taken by the controller to mitigate the risk;

    3. (3)

      the obligation to ensure that personal data is accurate and up to date, by informing the controller without delay if the processor becomes aware that the personal data it is processing is inaccurate or has become outdated;

    4. (4)

      the obligations in Article 32 of Regulation (EU) 2016/679.

  4. (d)

    The Parties shall set out in Annex III the appropriate technical and organisational measures by which the processor is required to assist the controller in the application of this Clause as well as the scope and the extent of the assistance required.

Clause 9: Notification of personal data breach

In the event of a personal data breach, the processor shall cooperate with and assist the controller for the controller to comply with its obligations under Articles 33 and 34 of Regulation (EU) 2016/679 or under Articles 34 and 35 of Regulation (EU) 2018/1725, where applicable, taking into account the nature of processing and the information available to the processor.

9.1 Data breach concerning data processed by the controller

In the event of a personal data breach concerning data processed by the controller, the processor shall assist the controller:

  1. (a)

    in notifying the personal data breach to the competent supervisory authority/ies, without undue delay after the controller has become aware of it, where relevant/(unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons);

  2. (b)

    in obtaining the following information which, pursuant to Article 33(3) of Regulation (EU) 2016/679, shall be stated in the controller’s notification, and must at least include:

    1. (1)

      the nature of the personal data including where possible, the categories and approximate number of data subjects concerned and the categories and approximate number of personal data records concerned;

    2. (2)

      the likely consequences of the personal data breach;

    3. (3)

      the measures taken or proposed to be taken by the controller to address the personal data breach, including, where appropriate, measures to mitigate its possible adverse effects.

Where, and insofar as, it is not possible to provide all this information at the same time, the initial notification shall contain the information then available and further information shall, as it becomes available, subsequently be provided without undue delay.

  1. (c)

    in complying, pursuant to Article 34 of Regulation (EU) 2016/679, with the obligation to communicate without undue delay the personal data breach to the data subject, when the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons.

9.2 Data breach concerning data processed by the processor

In the event of a personal data breach concerning data processed by the processor, the processor shall notify the controller without undue delay after the processor having become aware of the breach. Such notification shall contain, at least:

  1. (a)

    a description of the nature of the breach (including, where possible, the categories and approximate number of data subjects and data records concerned);

  2. (b)

    the details of a contact point where more information concerning the personal data breach can be obtained;

  3. (c)

    its likely consequences and the measures taken or proposed to be taken to address the breach, including to mitigate its possible adverse effects.

Where, and insofar as, it is not possible to provide all this information at the same time, the initial notification shall contain the information then available and further information shall, as it becomes available, subsequently be provided without undue delay.

The Parties shall set out in Annex III all other elements to be provided by the processor when assisting the controller in the compliance with the controller’s obligations under Articles 33 and 34 of Regulation (EU) 2016/679.

SECTION III: FINAL PROVISIONS

Clause 10: Non-compliance with the Clauses and termination

  1. (a)

    Without prejudice to any provisions of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725, in the event that the processor is in breach of its obligations under these Clauses, the controller may instruct the processor to suspend the processing of personal data until the latter complies with these Clauses or the contract is terminated. The processor shall promptly inform the controller in case it is unable to comply with these Clauses, for whatever reason.

  2. (b)

    The controller shall be entitled to terminate the contract insofar as it concerns processing of personal data in accordance with these Clauses if:

    1. (1)

      the processing of personal data by the processor has been suspended by the controller pursuant to point (a) and if compliance with these Clauses is not restored within a reasonable time and in any event within one month following suspension;

    2. (2)

      the processor is in substantial or persistent breach of these Clauses or its obligations under Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725;

    3. (3)

      the processor fails to comply with a binding decision of a competent court or the competent supervisory authority/ies regarding its obligations pursuant to these Clauses or to Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

  3. (c)

    The processor shall be entitled to terminate the contract insofar as it concerns processing of personal data under these Clauses where, after having informed the controller that its instructions infringe applicable legal requirements in accordance with Clause 7.1 (b), the controller insists on compliance with the instructions.

  4. (d)

    Following termination of the contract, the processor shall, at the choice of the controller, delete all personal data processed on behalf of the controller and certify to the controller that it has done so, or, return all the personal data to the controller and delete existing copies unless Union or Member State law requires storage of the personal data. Until the data is deleted or returned, the processor shall continue to ensure compliance with these Clauses.

ANNEX I: List of parties

Controller(s)

Name
The customer organisation that accepts these Clauses in the LicenseMeter portal
Address
As stated in the customer's LicenseMeter account
Contact person’s name, position and contact details
The workspace owner or admin who accepts these Clauses, with the email address of that account
Signature and accession date
Online acceptance in the LicenseMeter portal, recorded with the accepting user, the time and this document version

Processor(s)

Name
Ugurlabs UG (haftungsbeschränkt). Registered with the commercial register of the Local Court (Amtsgericht) of Düsseldorf under HRB 113979
Address
Fährstraße 217, 40221 Düsseldorf, Germany
Contact person’s name, position and contact details
Ugur Koc, Managing Director (Geschäftsführer), support@ugurlabs.com
Signature and accession date
Signed electronically by Ugur Koc, version 2.1, 19 September 2026

ANNEX II: Description of the processing

Categories of data subjects whose personal data is processed
The controller's employees and other directory users; holders of seats in connected source systems; the controller's own workspace members who sign in to the Service.
Categories of personal data processed
Display name; user principal name (UPN) / email address; directory object and tenant identifiers; account status and user type; account creation date; assigned license SKUs; last sign-in and per-workload last-activity timestamps; for connected source systems, seat email, status and product assignments; for workspace members, name, email, role and sign-in activity.
Sensitive data processed (if applicable) and applied restrictions or safeguards that fully take into consideration the nature of the data and the risks involved, such as for instance strict purpose limitation, access restrictions (including access only for staff having followed specialised training), keeping a record of access to the data, restrictions for onward transfers or additional security measures.
None. The Service is not intended for special categories of personal data (Art. 9 GDPR). Mailbox, file and message content is never accessed: the permissions the Service requests in the Microsoft 365 tenant are read-only and cover directory, license, sign-in activity and usage report data only.
Nature of the processing
Read-only collection, storage, aggregation and analysis of license, directory and activity metadata, and the generation of reports and exports from it. Synchronization runs on a schedule (typically nightly) and on demand when a user of the controller starts it.
Purpose(s) for which the personal data is processed on behalf of the controller
Solely to identify unused, oversized and misaligned license assignments and their cost, and to report them to the controller. The processor does not use the personal data to monitor or evaluate the performance or behavior of individual employees of the controller, does not create profiles for such purposes, and does not provide the Service as a tool for performance or behavior monitoring. Activity metadata is processed solely to determine whether a paid license seat is used, unused or oversized.
Duration of the processing
For as long as the workspace exists. The owner can delete the workspace at any time, which deletes all synchronized data, the activity log and the stored connection credentials immediately and irreversibly.
For processing by (sub-) processors, also specify subject matter, nature and duration of the processing
The sub-processors in Annex IV host the application, store the data, provide sign-in and deliver email, each for the purpose named there and for the duration of this agreement.

ANNEX III: Technical and organisational measures including technical and organisational measures to ensure the security of the data

The measures are listed under the headings the Clauses suggest. Each one describes how the Service is built and can be checked in its public source code.

Measures of pseudonymisation and encryption of personal data

  • Credentials for connected source systems (client secrets, API keys, certificate private keys) are encrypted at the application layer with AES-256-GCM before they are stored. The key is derived with HKDF-SHA256, and each ciphertext is bound to its workspace, provider and database column, so it cannot be decrypted in another context.
  • A dedicated data encryption key can be configured separately from the session signing secret, so that one can be rotated without the other.

Measures for ensuring ongoing confidentiality, integrity, availability and resilience of processing systems and services

  • Every request resolves the signed-in user's workspace membership on the server, and data is read and written scoped to that workspace. Identifiers sent by the browser are never trusted on their own.
  • In the hosted database, row-level security is enabled on every table. The application connects with a dedicated role that holds data manipulation rights only and owns no tables. The database provider's public Data API roles have no policy and no grants, so they cannot read or write anything.
  • Access to the Microsoft 365 tenant is read-only: User.Read.All, AuditLog.Read.All, Reports.Read.All, LicenseAssignment.Read.All and ReportSettings.Read.All. The Service holds no write permission and cannot change anything in the tenant. Remediation scripts are generated for the controller to review and run itself; the Service never executes them.
  • State-changing routes check the request origin, and sensitive endpoints such as synchronization, invitations and the support form are rate limited with counters kept in the database.
  • A content security policy, a ban on framing, MIME sniffing protection, a referrer policy and a permissions policy are sent with every response.
  • Synchronization tolerates missing optional permissions, and only one synchronization can run per workspace at a time.

Processes for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures in order to ensure the security of the processing

  • Every change runs through a continuous integration pipeline with formatting, lint and type checks, unit tests, end-to-end tests in a browser, and a dependency audit that fails on high-severity advisories.
  • Security reports are accepted under the policy published in SECURITY.md.

Measures for user identification and authorisation

  • Sign-in runs through Microsoft Entra ID with OpenID Connect and PKCE, limited to work and school accounts. ID tokens are verified against the issuer's published keys with the algorithm, audience and issuer pinned.
  • Sessions are signed tokens in cookies that are httpOnly, SameSite and, in production, Secure and bound to the exact host. A session lasts at most 30 days.
  • Workspace access is invite-based: signing in with an account from the same tenant grants nothing by itself. Invitations that are not claimed expire after 14 days. The roles owner, admin and viewer enforce least privilege, and the server checks the role on every page, route and action.

Measures for the protection of data during transmission

  • The Service is reachable over HTTPS only, with HTTP Strict Transport Security set to one year including subdomains. Microsoft Graph and all connected source systems are called over HTTPS.

Measures for the protection of data during storage

  • Connection credentials are stored only in encrypted form (see the first heading). Customer data is kept in one PostgreSQL database, separated per workspace by a workspace identifier on every record and protected by foreign key and uniqueness constraints.

Measures for ensuring physical security of locations at which personal data are processed

  • LicenseMeter operates no data centres or servers of its own. The application runs in the Frankfurt region of the hosting sub-processor, and the physical security of the locations is the responsibility of the sub-processors named in Annex IV.

Measures for ensuring events logging

  • A per-workspace activity log records exports, membership and role changes, connection changes and other administrative actions with the acting user and the time. Owners and admins can read and export it.
  • Every synchronization run is recorded with its status, steps and any error.

Measures for ensuring system configuration, including default configuration

  • Configuration is validated when the application starts, so it does not run with missing or malformed security settings.
  • Defaults are restrictive: a colleague who joins a workspace through its verified company domain starts as a viewer, and consumer email domains never join another user's workspace.

Measures for ensuring data minimisation

  • The Service requests only the permissions listed above and reads metadata only. Activity is stored as the date of the last sign-in and of the last use per workload, not as a record of what a person did.

Measures for ensuring data quality

  • Each synchronization reads the data again from the source system, so a correction made at the source reaches the Service with the next run.

Measures for ensuring limited data retention

  • Data is kept only while the workspace exists. Deleting the workspace removes every record that belongs to it through cascading deletes, including the activity log.

Measures for ensuring accountability

  • The acceptance of this agreement is recorded per workspace with the accepting user, the time, the language and the document version. Agreements signed with a named company are recorded the same way.

Measures for allowing data portability and ensuring erasure

  • Findings, licenses, the price book, remediation plans and the activity log can be exported as CSV, and the waste report as PDF.
  • An owner can delete the workspace in the settings at any time. The deletion is immediate and cannot be undone.

Assistance to the controller

  • Requests from data subjects: owners and admins can look up every user record in the portal, export the findings about it as CSV, and remove the data by disconnecting the source system or deleting the workspace. Requests that reach LicenseMeter directly are forwarded to the controller under Clause 8(a).
  • Personal data breaches: notifications under Clause 9.2 are sent by email to the owners and admins of the affected workspace. The contact point for more information is support@ugurlabs.com.

ANNEX IV: List of sub-processors

This is the agreed list of sub-processors under Clause 7.7(a), option 2. LicenseMeter announces an addition or replacement at least 30 days in advance.

  • Vercel Inc.

    Purpose
    Application hosting and content delivery
    Processing location
    EU (Frankfurt function region)
    Transfer mechanism
    EU processing; SCCs for any support access from outside the EU

  • Supabase Inc.

    Purpose
    Managed PostgreSQL database (primary data store)
    Processing location
    EU (AWS eu-central-1, Frankfurt)
    Transfer mechanism
    EU processing; SCCs for any support access from outside the EU

  • Microsoft (Microsoft Ireland Operations Ltd. / Microsoft Corporation)

    Purpose
    Identity platform (sign-in, admin consent) and Microsoft Graph API
    Processing location
    EU Data Boundary; US fallback
    Transfer mechanism
    EU Standard Contractual Clauses (Microsoft Products and Services DPA)

  • Resend Inc.

    Purpose
    Transactional and notification email delivery
    Processing location
    EU (Ireland region)
    Transfer mechanism
    EU processing; SCCs where applicable

To be distinguished from sub-processors are the optional source systems the controller connects (Adobe, Zoom, Atlassian, Salesforce, OpenAI, Anthropic) and any member lists the controller imports by CSV (ChatGPT, Claude). The processor reads from these systems on the controller's behalf on a read-only basis. They are data sources, not sub-processors of the processor; no personal data is disclosed to them beyond the authenticated read request. Where the controller connects a Microsoft tenant using its own app registration ('bring your own'), the credentials supplied (client secret or certificate private key) are stored encrypted at rest (AES-256-GCM) and used solely to perform the read-only Microsoft Graph sync.

Signatures

This agreement is pre-signed by LicenseMeter. The customer accepts it online in the LicenseMeter portal, where the acceptance is recorded. Customers whose internal process requires a counter-signed copy can sign below and keep it for their files.

For the processor

Ugurlabs UG (haftungsbeschränkt)

Registered with the commercial register of the Local Court (Amtsgericht) of Düsseldorf under HRB 113979

Name: Ugur Koc

Title: Managing Director (Geschäftsführer)

Signed electronically by Ugur Koc, version 2.1, 19 September 2026

For the controller

Legal entity: ____________________________

Name: ____________________________

Title: ____________________________

Place / Date: ____________________________

Signature: ____________________________