FLEXPRICE DHS

Data Handling Statement

Last Updated: July 20, 2026

Squirrelly Technologies Private Limited ("Flexprice")

This Data Handling Statement ("Statement") explains how the Flexprice platform and services (the "Services") handle data, and why the Services are not offered on the basis of a traditional processor data-processing agreement. It forms part of, and is incorporated by reference into, the Master Terms of Service (the "Master Terms"), and should be read together with the data-handling provisions of the Master Terms and the Privacy Policy. Capitalised terms used but not defined here have the meanings given in the Master Terms. If this Statement and the Master Terms conflict, the Master Terms prevail, except that this Statement governs the specific data-handling characteristics it describes.


1. HOW FLEXPRICE PROCESSES DATA

1.1 Where the Metering Data and other Customer Data processed through the Services contain personal data, Flexprice acts as processor and the Customer (or the third party for whom the Customer acts) acts as controller. Flexprice processes and, to the extent necessary to provide the Services, stores that personal data on the Customer's behalf. The data-processing terms governing that processing are set out in Clause 8 (Data Handling and Privacy) of the Master Terms, which operates as the parties' data-processing agreement; a separate standalone data-processing agreement is therefore not required. This Statement summarises how data flows through the Services and should be read together with Clause 8 of the Master Terms and the Privacy Policy, which prevail over this Statement in the event of any conflict.

1.2 If the parties agree in writing that Flexprice will process Customer personal data for a specific purpose beyond the provision of the Services, they may enter into supplementary data-processing terms for that purpose, which will govern that processing in addition to Clause 8 of the Master Terms.


2. THE TWO CATEGORIES OF DATA

2.1 Metering Data. The events, usage records, counters, and associated metadata that the Customer transmits to, or generates through, the Services for metering, rating, pricing, and billing. Metering Data is processed, and to the extent necessary stored, to produce metering and billing outputs. Where Metering Data contains personal data, Flexprice processes it as processor on the Customer's behalf under Clause 8 of the Master Terms. The Customer, as controller, determines and is responsible for the personal data it includes in the Metering Data.

2.2 Customer Identification Data. The account, contact, billing, and administrative details of the Customer and its authorised Users that Flexprice holds, as controller, to establish, administer, support, secure, and bill the Customer's account. Flexprice's handling of Customer Identification Data is described in the Privacy Policy.


Metering Data

Customer Identification Data

Flexprice's role

Processor

Controller

Stored by Flexprice?

Yes — on the Customer's behalf, to provide the Services

Yes — to run the account

Governing document

Master Terms (Clause 8) + this Statement

Privacy Policy

Used to train AI models?

No

No

3. HOW METERING DATA FLOWS

3.1 The Customer sends usage events to the Services through the Customer's integration. The Services meter and rate those events and return metering and billing outputs. Where those events contain personal data, Flexprice processes and stores it as processor on the Customer's behalf, solely to provide the Services and in accordance with Clause 8 of the Master Terms. The Customer, as controller, determines and is responsible for the personal data it submits.


4. SECURITY

4.1 Flexprice maintains reasonable and appropriate administrative, technical, and organisational measures designed to protect data in its control against accidental or unlawful loss, access, or disclosure, taking into account the nature of the Services and the state of the art. Flexprice's incident-notification commitments are set out in the Master Terms.


5. SUBPROCESSORS AND TRANSFERS

5.1 Flexprice may engage Affiliates and third-party providers ("Subprocessors") to help provide, host, secure, and support the Services, under obligations to protect data consistent with the Master Terms and the Privacy Policy. Flexprice may process Customer Identification Data in India and in other jurisdictions in which it or its Subprocessors operate, and takes the steps required by Applicable Law for any cross-border transfer. Because Flexprice processes and stores Customer personal data as processor to provide the Services, any cross-border transfer of that personal data is subject to the transfer safeguards required by Applicable Law and to Clause 8 of the Master Terms.


6. ON-PREMISE DEPLOYMENTS

6.1 For an on-premise deployment, the Customer Data and any Metering Data reside within the Customer's environment and are not transmitted to or hosted by Flexprice in the ordinary course. The Customer is the controller and custodian of that data. The On-Premise Deployment Addendum sets out the parties' responsibilities for that deployment.


7. CHANGES

7.1 Flexprice may update this Statement from time to time in accordance with the change-of-terms provision of the Master Terms. The current version is published at the Flexprice website, and the "Last Updated" date above reflects the most recent change.

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