Data Processing Addendum (DPA) – Argyle Satellite Ltd

Updated June 2026

DATA PROCESSING ADDENDUM – ARGYLE SATELLITE LTD

This Data Processing Addendum (“DPA”) forms part of and is incorporated into the Argyle Satellite Ltd Terms and Conditions for Business Accounts (the “Terms”) and applies to Argyle Satellite Ltd’s (“we”, “us”, “our”) processing of the personal data supplied by you to us in connection with the provision of our Services.
1. Definitions and interpretation
1.1 In this DPA defined terms shall have the same meaning, and the same rules of interpretation shall apply as in the Terms. In addition, in this DPA the following definitions have the meanings given below:
(a) Controller, Processor, Data Subject, Personal Data, Personal Data Breach, processing, Personal Data Breach, Supervisory Authority and appropriate technical and organisational measures: shall have the meanings given in the Data Protection Legislation;
(b) Data Protection Legislation: all applicable data protection and privacy legislation in force from time to time in the UK including the UK GDPR; the Data Protection Act 2018 (DPA 2018) (and regulations made thereunder) and the Privacy and Electronic Communications Regulations 2003 (SI 2003/2426) as amended and all other legislation and regulatory requirements in force from time to time which apply to a party relating to the use of Personal Data (including, without limitation, the privacy of electronic communications); and
(c) Processed Data: means Personal Data provided by you to us in relation to the Services as a set out at the Annex to this DPA.
2. Data Processing
2.1 Each party shall:
(a) at all times whilst using or providing (as applicable) the Services, comply with the Data Protection Legislation;
(b) to the extent applicable under the Data Protection Legislation, obtain and maintain all appropriate registrations required in order to allow that party to perform its obligations under the Terms; and
(c) notify each other of an individual within its organisation authorised to respond from time to time to enquiries regarding personal data.
2.2 We:
(a) acknowledge that, in respect of Processed Data, as between the parties, we act as a processor; and
(b) shall ensure that all of our personnel who have access to and/or process Processed Data are obliged to keep the personal data confidential.
2.3 Subject to clause 2.7, we:
(a) shall only process Processed Data in accordance with the Terms and your instructions as set out in the Terms and as issued from time to time ("Processing Instructions") (which you shall ensure are compliant with the Data Protection Legislation). For the avoidance of doubt, the Terms constitute your instructions to us and we are further instructed to:
(i) process personal data to communicate directly with data subjects for the purpose of providing and promoting the Services;
(ii) process personal data to communicate directly to data subjects for the purpose of promoting consumer services, and you warrant that you have attained appropriate consents for this communication;
(iii) process personal data to communicate directly with data subjects for the purpose of requesting that data subjects participate in surveys to improve customer experience;
(b) if applicable laws require us to process Processed Data other than in accordance with the Processing Instructions, shall notify you of any such requirement before processing the Processed Data (unless applicable laws prohibits such information on important grounds of public interest);
(c) shall inform you if we become aware of a Processing Instruction that, in our opinion, infringes Data Protection Legislation, provided that this provision is without prejudice to clause 2.1;
(d) shall provide reasonable cooperation and assistance to you in ensuring compliance with:
(i) your obligations to respond to any complaint or request from any applicable data protection authority or data subjects seeking to exercise their rights under any Data Protection Legislation as they relate to the Terms;
(ii) your obligations set out under the Data Protection Legislation, including to:
(A) ensure the security of the processing;
(B) notify the relevant Supervisory Authority and any data subjects, where relevant, of any Personal Data Breach;
(C) carry out any data protection impact assessments ("DPIA") on the impact of the processing on the protection of Processed Data; and
(D) consult the relevant Supervisory Authority prior to any processing where a DPIA indicates that the processing would result in a high risk in the absence of measures taken by you to mitigate the risk;
(e) notify you without undue delay on becoming aware of a Personal Data Breach in respect of Processed Data processed under the Terms;
(f) shall make available to you all information reasonably required by you to demonstrate our compliance with our obligations set out in this DPA and allow and co-operate with any data protection audits and inspections conducted by you or another auditor mandated by you, provided that reasonable prior notice is provided, and no more than one such audit or inspection is conducted during any 12-Month period unless mandated by a Supervisory Authority;
(g) taking into account the nature of and risks associated with the type of personal data collected or used in connection with the Services, shall have in place appropriate technical and organizational measures to ensure a level of security appropriate to the risks that are presented by the processing of personal data by or on behalf of us including where appropriate data protection by default and/or by design measures, and all other such measures as may be agreed between the parties; and
(h) at the written direction of you, delete or return Processed Data and copies thereof to you on termination of the Terms unless required by applicable laws and/or permitted under applicable Data Protection Legislation to store the Processed Data.
2.4 The provision of the Services may require the transfer of personal data to countries outside the UK and the EEA from time to time. Subject to clause 2.5, we and our sub-processors shall not, without the prior written consent of you, transfer any Processed Data to a country or territory outside the UK or the EEA unless adequate contractual or other assurances have first been put in place such as will enable each party to comply with the requirements of the Data Protection Legislation.
2.5 You hereby grant to us general authorisation for sub-processing (including, without limitation, Group Members and in respect of our drivers), provided that:
(i) we and the sub-processor enter into a contract on terms substantially as protective as this DPA;
(ii) we shall keep you informed from time to time of any intended changes concerning the addition or replacement of any categories of sub-processors engaged in the provision of the Services; and
(iii) we shall remain fully liable to you for the performance of the sub-processor's obligations.
2.6 The parties acknowledge that the types of personal data processed pursuant to the Terms (i.e. Processed Data) (including the subject matter, duration, nature and purpose of the processing and the categories of data subject) are as described in the Annex.
2.7 If and to the extent we are a data controller in relation to personal data collected under the Terms, we shall comply with the applicable provisions of the Data Protection Legislation.

ANNEX – PROCESSED DATA
For the purposes of this DPA, the parties set out below a description of the Processed Data being processed in connection with our provision of the Services and further detail required pursuant to Data Protection Legislation.
1. Types of personal data
Name, title, job title, mobile phone number, email address, business contact details, private address (including previous residential addresses), private contact details, booking data such as date and time, records of complaints and lost property, bank account or, credit/debit card information, regulatory information, telematics data, geo-location data, wifi usage data, any notes taken to help deliver the ground transportation services and health data (where applicable).
2. Duration of processing
Until the latest of (a) the date upon which processing is no longer necessary for the purposes of either party performing its respective obligations under the Terms (to the extent applicable); or (b) processing for the purpose of compliance with applicable laws and/or regulatory requirements.
3. Nature of processing
Collection, storage, duplication, transfer, electronic viewing, deletion and destruction.
4. Purpose of processing
The provision of ground transportation services, to communicate directly with data subjects for the purpose of providing and promoting the Services, to process personal data to communicate directly to data subjects for the purpose of promoting consumer services, and to process personal data to communicate directly with data subjects for the purpose of requesting that data subjects participate in surveys to improve customer experience.
5. Categories of data subject
Customers, officers, employees and temporary staff, partners, complainants, correspondents, enquirers, suppliers, advisers, consultants, professional experts and anyone else authorised by the you to use the Services.