Essence of data processing agreement

The joint controllers have allocated their roles and responsibilities as follows:

Name and address of joint

Lead Controller or Joint

Function / Role with regard to
Joint Processing

Control over Joint Processing

Groundspeak Inc.
837 N. 34th Street,
Suite 300 Seattle,
WA 98103, USA

Lead Joint Controller being data importer

  • Design of data Processing activity
  • Ensure compliance with Applicable Privacy Law
  • Information to Data Subjects
  • Contact Point for Data Subjects
  • Handling Data Subject Access Rights
  • Data breach notifications
  • DPIA and other overall governance documentation
  • Engaging Processors · Own ROPA
  • Perform the information and notification obligations of the Other Joint Controller as set forth by the EU SCC

Lead over all Processing activities.

Lead Controller will provide Joint Controller with access to the Adventure Lab Builder for purposes of creating Adventures. Lead Controller will have sole responsibility for providing, hosting, and maintaining the Adventure Lab App, the Adventure Lab Builder, the Site, its associated mobile applications, and associated services.

Comet AG
Herrengasse 10
3175 Flamatt


Joint Controller being data exporter

Ensure compliance with local Applicable Privacy Law

  • Local information and contact point for Participants (also referred to herein as “Data Subjects”)
  • Assist Lead Controller in handling Data Subject Access Rights
  • Data breach notifications (only breaches not notified by Lead Controller)
  • DPIA and other governance documentation, if and to the extent required only under local Applicable Privacy Law
  • Own ROPA

Processing described in the Principal Agreement in particular it will be responsible for providing all content for the Adventures.