Data Protection Addendum

Fast Friends App Data Protection Addendum

Version 1.0
Last Updated: March 9, 2026

This Data Protection Addendum (“Addendum”) applies to the processing of Personal Data by GJS Technologies, LLC, DBA Fast Friends App (“Fast Friends”) in connection with the Services provided to you (“Customer”) under the applicable Terms of Service or other written agreement (the “Agreement”). This Addendum addresses compliance with applicable data protection laws, including the EU GDPR, UK GDPR, and California Consumer Privacy Act (CCPA).

For the purposes of this Addendum:

European Personal Data includes Personal Data of individuals in the EU/EEA or Switzerland (EU GDPR) or the UK (UK GDPR).
CA Personal Data includes Personal Data of California residents under the CCPA.
Terms like “Controller,” “Processor,” “data subject,” and “process” have the meanings defined under applicable law.

This Addendum supplements the Agreement. In case of conflict, the provisions of this Addendum govern.

1. Nature of Processing

Scope: Fast Friends processes Personal Data to provide the Services, including onboarding, engagement, and workplace interaction tools.
Categories of Data Subjects: Employees, contractors, or other individuals whose data is processed under the Services.
Types of Personal Data: Name, email address, profile information, messages, and other content submitted through the Services.

2. Compliance with Laws

Both parties agree to comply with applicable Privacy Laws:

GDPR (EU & UK) for European Personal Data.
CCPA for California residents.
Any other applicable privacy, data protection, or security requirements.

3. Customer Obligations

Customer shall:

Determine the purpose and lawful basis for processing Personal Data.
Provide instructions to Fast Friends regarding data processing.
Ensure Personal Data is collected lawfully and is accurate, relevant, and proportionate.
Comply with applicable data protection obligations, including obtaining consents, responding to data subject requests, and ensuring personnel comply with this Addendum.

By entering this Addendum, Customer instructs Fast Friends to process Personal Data only as necessary to provide the Services or as otherwise agreed in writing.

4. Fast Friends Obligations

Fast Friends, as Processor, shall:

Process Personal Data only to provide the Services in accordance with Customer instructions.
Not sell, share, or use Personal Data for independent purposes.
Implement appropriate organizational and technical security measures, including encryption, access controls, and monitoring.
Limit access to Personal Data to personnel with a legitimate business need under confidentiality obligations.
Engage subprocessors only with Customer notice and under equivalent data protection obligations; Customer may object in writing within 15 days.
Comply with AI/ML restrictions: Customer Personal Data will not be used to train AI/ML models independently by Fast Friends or subprocessors.
Notify Customer promptly of any:
- Legal requests for data disclosure,
- Investigations by Supervisory Authorities, or
- Personal Data Breaches (within 72 hours of discovery).
Assist Customer with data subject requests, breach investigations, notifications to authorities, and data protection impact assessments.
Inform Customer if legally required to process Personal Data outside the scope of instructions.

5. Audit

Customer may audit Fast Friends’ compliance with this Addendum once per year. Audits will be:

Conducted during business hours, with reasonable notice, and in a manner that does not disrupt operations.
Subject to confidentiality restrictions.
Used only for regulatory compliance or verification of this Addendum.

6. Data Transfers

Fast Friends may store or process data in the U.S. or other countries.
EU/UK Restricted Transfers: Any transfers outside the EEA or UK will comply with the Standard Contractual Clauses or other legally recognized mechanisms.
Subprocessor transfers are governed by the same obligations.

7. Data Return and Deletion

Upon termination of the Agreement or Services:

Fast Friends will delete or return Personal Data upon Customer request.
If legal requirements prevent deletion, Fast Friends will continue to protect the data and only process as legally required.

8. Liability

Liability for breaches of this Addendum is subject to the caps in the Agreement.
Nothing limits data subject rights under GDPR, UK GDPR, or CCPA where legally prohibited.

9. Amendments

Fast Friends may update this Addendum to comply with new laws or regulations. Notice may be given via email, Service dashboard, or website. Continued use of the Services constitutes acceptance.