FleetOS Data Processing Addendum — Syria

Version: 5.7.2 Effective date: August 20, 2026 Market: Syria

1. Scope and roles

This Addendum applies where the Local FleetOS Entity named in the Office’s Order Form processes personal data on behalf of and on the documented instructions of that Office. It forms part of FOS-06 for that country market only. No other FleetOS market entity is a processor or subprocessor merely because it shares branding, ownership, directors, infrastructure or technology.

FleetOS Direct data. This Addendum governs Office-controlled data only. Personal data processed by the Local FleetOS Entity for its own FleetOS Direct transportation operation is controlled under FOS-02 and is not Office-processor data under this Addendum.

2. Instructions

We process personal data only on your documented instructions, which are: this Addendum; FOS-06; the Order Form; and any further written instruction you give that is within the scope of the service.

We will tell you if we consider an instruction infringes applicable data protection law, and may suspend that processing until it is resolved. Where law requires us to process otherwise than on your instruction, we will tell you first unless the law prohibits it.

3. Confidentiality and personnel

Personnel with access to personal data are bound by written confidentiality obligations, are trained, and have access only on a least-privilege basis, reviewed at least quarterly.

4. Security

We implement the technical and organisational measures in FOS-06 Schedule 3. We may update them provided the level of protection is not materially reduced.

5. Subprocessors

5.1 General authorisation

You give general authorisation for us to engage subprocessors. The current list is in Schedule 2 and is published in the Legal Center.

5.2 Changes

We give at least 30 days' notice before adding or replacing a subprocessor. You may object on reasonable data protection grounds within 15 days, stating the grounds. We will work in good faith to resolve the objection; if we cannot, you may terminate the affected service with a pro-rata refund of prepaid unused fees.

5.3 Our responsibility

We impose obligations on each subprocessor at least as protective as this Addendum and remain contractually responsible for its processing to the extent required by applicable law and this Addendum. That responsibility is subject to FOS-06 §23, including the Data/Security Supercap in §23.3A, except to the extent applicable law prohibits limitation.

Other FleetOS market entities. A company operating FleetOS in another country may process Office Data only if it is specifically identified in Schedule 2 as a subprocessor or other lawful recipient, an appropriate written intercompany processing agreement is in force, access is least-privilege and purpose-limited, and every required international-transfer mechanism has been completed. Common branding or ownership is not authorisation to access Office Data.

6. Assistance to you

We will assist you, at your cost where the assistance is not trivial, with: responding to individual rights requests; data protection impact assessments; prior consultation with a regulator; and demonstrating compliance.

Where an individual contacts us directly about processing for which you are controller, we will not respond substantively; we will forward the request to you within 5 business days and tell the individual we have done so.

7. Personal data breach

We will notify you of a confirmed personal data breach affecting your personal data without undue delay and, as a contractual target, within 24 hours of confirmation, subject only to the investigation necessary to make the notification meaningful.

Our notification will describe, to the extent known: the nature of the breach; the categories and approximate number of individuals and records; the likely consequences; the measures taken or proposed; and a contact point. We will provide updates as the investigation develops and will assist you with your own notification obligations.

"Confirmation" means the point at which we determine a breach has occurred, not the point at which we first receive an alert. We do not delay confirmation to defer the clock.

8. Deletion and return

On termination, and at your written election made within 30 days, we will return or delete personal data processed on your behalf, except where we must retain it under applicable law, for a legal hold, or for the defence of a claim. Backups are deleted on their ordinary cycle. We will confirm deletion in writing on request.

9. Audit

We will make available the information reasonably necessary to demonstrate compliance, including our current certifications and penetration test summary under NDA.

You may audit no more than once in any 12 months, on at least 30 days' notice, during business hours, subject to confidentiality, and at your cost — unless the audit reveals material non-compliance, in which case we bear our own costs and reimburse yours. We may satisfy an audit request by providing a recent third-party audit report where it reasonably addresses your scope. Additional audits may be conducted following a personal data breach or a regulator direction.

10. International transfers

Transfers are made only on the basis recorded in Schedule 2 for the relevant country market. Market data is logically partitioned by Local FleetOS Entity. Where a transfer requires a specific mechanism — standard contractual clauses, adequacy decision, approved contractual terms, consent or another lawful basis — that mechanism is identified before the transfer occurs and is a condition of activating the recipient or market.

11. Liability

Liability under this Addendum is subject to FOS-06 §23, including the Data/Security Supercap in §23.3A, except where applicable law prohibits limitation of liability for a particular data-protection obligation, in which case the limitation applies only to the maximum lawful extent.

Schedule 1 — Processing details

Schedule 2 — Subprocessor and data-location register

The Approved Subprocessor and Data-Location Register is the subprocessor/data section of the FleetOS compliance record for the applicable country market. The public-facing version is displayed in the FleetOS Legal Center and is incorporated into this Addendum by reference. The version displayed to the Office at acceptance is retained with the Office’s agreement evidence.

For each approved subprocessor, the register identifies at least: legal name; service; categories of data processed; principal processing location(s); applicable transfer basis or safeguard where required; and the country market(s) for which the subprocessor is approved. A FleetOS entity from another country is not an implicit subprocessor and must be specifically listed if it will process Office Data on behalf of the Local FleetOS Entity.

FleetOS will not intentionally permit a new subprocessor to process Office Data before it has completed appropriate due diligence, entered into written data-protection terms, and added that subprocessor to the approved register. Changes are subject to the notice and objection procedure in §5.2.

The register also identifies the approved primary hosting and backup regions for the applicable market and any transfer or localisation safeguard applicable to that deployment. If a processing activity requires a subprocessor, hosting location or transfer mechanism that has not been approved and published for the market, that processing activity is not enabled until the register is updated in accordance with this Addendum.

Schedule 3 — Data retention register

This Schedule is the authoritative source for retention. FOS-02 §8 summarises it; where they differ, this Schedule controls.

Legal hold overrides everything in this table. Where litigation, a regulatory investigation or a preservation obligation is reasonably anticipated, deletion is suspended for the affected records until the hold is released by the person who imposed it.