This SCC / UK Transfer Addendum (“Addendum”) forms part of the Data Processing Agreement (“DPA”) between FOP Kushnir Denis Olehovych (“Helveris” or “Data Importer,” where applicable) and the Customer (“Data Exporter,” where applicable).
This Addendum applies only to the extent that Customer Personal Data subject to EU GDPR or UK GDPR is transferred to Helveris, or to an onward recipient, in a jurisdiction that is not covered by an adequacy decision or other lawful exemption under applicable data protection law. [oai_citation:0‡helveris.com](https://helveris.com/ssk-uk-addendum/)
1. EU Standard Contractual Clauses
To the extent required for transfers of Personal Data subject to the EU GDPR, the parties agree that the European Commission Standard Contractual Clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 (“EU SCCs”) are incorporated by reference into this Addendum. [oai_citation:1‡helveris.com](https://helveris.com/ssk-uk-addendum/)
1.1 Module
Module Two (Controller to Processor) applies where the Customer is a Controller and Helveris is a Processor. If the factual relationship changes for a specific processing activity, the parties may apply the appropriate module required by law. [oai_citation:2‡helveris.com](https://helveris.com/ssk-uk-addendum/)
1.2 Clause 7
The optional docking clause in Clause 7 applies. [oai_citation:3‡helveris.com](https://helveris.com/ssk-uk-addendum/)
1.3 Clause 9
Option 2 in Clause 9 applies, and the time period for prior notice of new Subprocessors will be a reasonable notice period, which may be provided by email, account notice, website posting, or other written means. [oai_citation:4‡helveris.com](https://helveris.com/ssk-uk-addendum/)
1.4 Clause 11
The optional language in Clause 11 regarding an independent dispute resolution body does not apply unless otherwise agreed in writing. [oai_citation:5‡helveris.com](https://helveris.com/ssk-uk-addendum/)
1.5 Clause 17
The governing law of the EU SCCs will be the law of an EU Member State that allows for third-party beneficiary rights. If no such law is specified by the Customer, the law of Ireland will apply. [oai_citation:6‡helveris.com](https://helveris.com/ssk-uk-addendum/)
1.6 Clause 18
The courts of Ireland will have jurisdiction, unless the parties are required by applicable law to select another EU Member State. [oai_citation:7‡helveris.com](https://helveris.com/ssk-uk-addendum/)
1.7 Annex I
Annex I to the EU SCCs is deemed completed with the information set out in the DPA, including the parties, description of transfer, categories of data subjects, categories of personal data, frequency and purpose of transfer, duration, and contact details. [oai_citation:8‡helveris.com](https://helveris.com/ssk-uk-addendum/)
1.8 Annex II
Annex II to the EU SCCs is deemed completed with the technical and organizational measures described in the DPA and its security annex. [oai_citation:9‡helveris.com](https://helveris.com/ssk-uk-addendum/)
1.9 Annex III
Annex III to the EU SCCs is deemed completed with the list or categories of Subprocessors authorized under the DPA. [oai_citation:10‡helveris.com](https://helveris.com/ssk-uk-addendum/)
This Addendum is intended to support lawful international transfers in connection with Helveris website workflows, including website assistance, lead routing, CRM handoff, and related customer support operations, where such transfers are subject to EU GDPR or UK GDPR.
2. UK International Data Transfer Addendum
To the extent required for transfers of Personal Data subject to the UK GDPR, the parties agree that the UK International Data Transfer Addendum issued by the UK Information Commissioner’s Office (“UK Addendum”) is incorporated by reference into this Addendum. The UK Addendum applies to the EU SCCs as incorporated above, with the Customer as exporter where applicable, Helveris as importer where applicable, and the relevant tables deemed completed using the information set out in the DPA, this Addendum, and the Agreement. [oai_citation:11‡helveris.com](https://helveris.com/ssk-uk-addendum/)
3. Priority
Where this SCC / UK Transfer Addendum applies, it prevails over the DPA and the Agreement only to the extent necessary to lawfully govern the relevant international transfer of Personal Data. [oai_citation:12‡helveris.com](https://helveris.com/ssk-uk-addendum/)
4. Interpretation
If any provision of this Addendum conflicts with the EU SCCs or the UK Addendum, the relevant SCCs or UK Addendum will prevail to the extent of that conflict. [oai_citation:13‡helveris.com](https://helveris.com/ssk-uk-addendum/)
5. Termination of Transfers
If Helveris can no longer comply with the EU SCCs, the UK Addendum, or any other applicable transfer safeguard, Helveris will promptly notify the Customer and the parties will cooperate in good faith to suspend the affected transfer, implement an alternative lawful transfer mechanism, or terminate the affected processing if necessary. [oai_citation:14‡helveris.com](https://helveris.com/ssk-uk-addendum/)
6. Supplementary Measures
Where required by applicable law, Helveris will implement reasonable supplementary technical, organizational, or contractual measures to support the lawfulness of the transfer, taking into account the nature of the processing and the risks involved. [oai_citation:15‡helveris.com](https://helveris.com/ssk-uk-addendum/)
7. Sensitive Data
Unless otherwise expressly agreed in writing, the Customer must not intentionally transfer special categories of personal data or criminal offence data through the Service. If such data is transferred, the Customer remains responsible for ensuring that appropriate additional safeguards and legal bases are in place. [oai_citation:16‡helveris.com](https://helveris.com/ssk-uk-addendum/)
8. Controlled Service Environment
Helveris is designed for website-specific business workflows rather than for use as a public AI system. Customers remain responsible for determining whether their website deployment, CRM routing, support workflows, and data handling practices are appropriate for the categories of Personal Data they choose to transfer.
9. Contact
If you have questions about this SCC / UK Transfer Addendum, our DPA, or the way Helveris supports privacy-aware website operations, please contact us at: