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Kolabtree Freelancer Data Processing Addendum

Last Updated: April 28, 2026

This Freelancer Data Processing Addendum (“DPA”) forms part of the Freelancer Terms of Use between Cactus Communications Limited and its Affiliates (“Kolabtree”) and the Freelancer.

This DPA governs the processing of Personal Data by Freelancers in connection with the Services provided through the Kolabtree platform.

1. Definitions

“Applicable Data Protection Laws” means all applicable laws relating to the protection, processing, or privacy of Personal Data that apply to the Freelancer or Kolabtree in connection with the Services.

“Personal Data” means any information relating to an identified or identifiable individual processed in connection with the Services.

“Processing” means any operation performed on Personal Data including collection, access, storage, use, disclosure, or deletion.

“Client Data” means any Personal Data contained in Client Materials or otherwise shared with the Freelancer through the Kolabtree platform.

2. Scope of Processing

Freelancers may access and process Personal Data in connection with providing Services requested by Clients through the Kolabtree platform.

Such Personal Data may include information relating to:

  • Client representatives
  • individuals referenced in project materials
  • other individuals whose information is contained in Client Materials or communications.

Freelancers may process such Personal Data solely for the purpose of performing Services requested through the platform.

3. Role of the Freelancer

The Freelancer processes Personal Data only as necessary to perform the Services requested by Kolabtree or its Clients.

The Freelancer shall not:

  • process Personal Data for any purpose other than providing the Services;
  • disclose Personal Data to third parties except as permitted under this Agreement;
  • retain Personal Data longer than necessary to perform the Services.
4. Confidentiality and Data Protection

Freelancers shall treat all Personal Data received through the platform as Confidential Information in accordance with the Freelancer Terms.

Freelancers must:

  • access Personal Data only when necessary to perform the Services;
  • ensure that Personal Data is not disclosed to unauthorized persons;
  • maintain appropriate safeguards to protect Personal Data.
5. Security Measures

Freelancers must implement reasonable technical and organizational measures to protect Personal Data, including:

  • maintaining secure devices and systems used for performing Services
  • using up-to-date security software and operating system updates
  • protecting access credentials used for accessing the platform
  • preventing unauthorized access to Client Materials and Personal Data.

Freelancers must ensure that Personal Data is not stored on insecure or publicly accessible systems.

6. International Nature of the Services

Freelancers acknowledge that Clients using the Kolabtree platform may be located in multiple jurisdictions worldwide.

Freelancers may therefore access Personal Data originating from jurisdictions outside the Freelancer’s country of residence.

Freelancers agree to process such Personal Data in compliance with Applicable Data Protection Laws and the obligations set out in this DPA.

7. Subcontracting

Freelancers shall not allow third parties to access Personal Data obtained through the platform unless:

  • such access is approved in writing by the Client and/or Kolabtree; and
  • the Freelancer ensures that such third party is bound by confidentiality and data protection obligations equivalent to those set out in this Agreement.

The Freelancer remains fully responsible for the acts and omissions of such third parties.

8. Data Breaches

If the Freelancer becomes aware of any unauthorized access, loss, disclosure, or compromise of Personal Data obtained through the platform, the Freelancer must notify Kolabtree without undue delay.

The Freelancer shall cooperate with Kolabtree in investigating and resolving such incidents.

9. Return or Deletion of Personal Data

Upon completion of the Services or upon Kolabtree’s request, the Freelancer must:

  • delete or return any Personal Data obtained through the platform, unless retention is required by law.

Freelancers must not retain copies of Personal Data after the project has been completed except where necessary for legal compliance.

10. Compliance

Freelancers agree to comply with:

  • this DPA
  • the confidentiality obligations set out in the Freelancer Terms
  • all Applicable Data Protection Laws.

Failure to comply with these obligations may result in suspension or termination of the Freelancer’s access to the platform.