Data Processing Addendum

Effective Date: July 21, 2026

Last Revised: Not yet revised

Version: 1.0

1. Purpose

This DPA establishes the respective responsibilities of Diversified Payday and the Customer regarding the processing of Customer Data.

Where this DPA applies, it supplements the Terms and Conditions. If there is a conflict between this DPA and the Terms regarding Customer Data processing, this DPA governs that processing to the extent of the conflict.

2. Definitions

For purposes of this DPA:

Customer means the business entity using Diversified Payday.

Customer Data means information submitted to or generated within the Services on behalf of the Customer.

Personal Information includes information relating to an identified or reasonably identifiable individual, where applicable law uses that concept.

Processing means collecting, storing, using, transmitting, organizing, accessing, disclosing, deleting, or otherwise handling Customer Data.

3. Scope

This DPA applies only to Customer Data processed through Diversified Payday services.

It does not apply to:

• Information Diversified Payday processes as its own business records.
• Public website information not associated with Customer accounts.
• Information processed outside the Services.
• Information processed solely for legal compliance, fraud prevention, security, or preservation of business records where permitted by law.

4. Processing Instructions

Diversified Payday will process Customer Data only:

• To provide the Services.
• To fulfill Customer instructions through the platform.
• To maintain and secure the Services.
• To comply with applicable law.
• To investigate fraud or misuse.
• To enforce agreements.
• For other compatible business purposes permitted by applicable law.

The Customer remains responsible for determining whether its instructions comply with applicable law.

5. Customer Responsibilities

The Customer is responsible for:

• Determining the lawful basis for processing.
• Providing required notices.
• Obtaining required consents where applicable.
• Maintaining accurate information.
• Determining worker classification.
• Determining payroll calculations.
• Determining tax obligations.
• Reviewing payroll before approval.
• Managing user permissions.
• Protecting credentials.

6. Diversified Payday Responsibilities

Diversified Payday will use reasonable administrative, technical, and organizational safeguards intended to protect Customer Data.

Diversified Payday may improve, modify, or replace security measures as technology and business needs evolve.

Nothing in this DPA guarantees any particular technology, certification, audit, encryption method, or security framework.

7. Confidentiality

Diversified Payday personnel with access to Customer Data are expected to maintain appropriate confidentiality obligations.

Access is limited to personnel with a legitimate business need or other authorized purpose.

8. Authorized Service Providers

Diversified Payday may use carefully selected service providers to assist in providing the Services.

Such providers may assist with functions including:

• Cloud hosting
• Email delivery
• SMS communications
• Payment processing
• Tax filing
• Customer support
• Analytics
• Security monitoring
• Infrastructure

Diversified Payday remains responsible for managing those relationships consistent with applicable law and contractual obligations.

9. Security Incidents

If Diversified Payday becomes aware of a security incident affecting Customer Data, Diversified Payday will respond in accordance with applicable law, contractual obligations, and internal incident-response procedures.

Notification timing and content may vary depending upon the nature of the incident and applicable legal requirements.

10. Customer Requests

Customers remain responsible for responding to requests from their employees, contractors, applicants, or other individuals concerning Customer Data unless applicable law requires otherwise.

Diversified Payday may reasonably assist where appropriate.

11. Retention and Deletion

Customer Data is retained according to the Diversified Payday Data Retention and Deletion Policy.

Upon expiration of applicable retention periods or lawful business needs, Diversified Payday may delete Customer Data in accordance with that policy.

12. International Processing

Diversified Payday currently offers services primarily for businesses operating within the United States.

If Customer Data is processed in another jurisdiction, such processing will occur in accordance with applicable law.

Nothing in this DPA constitutes adoption of any specific international transfer mechanism unless separately agreed in writing.

13. Audits and Information

Customers may request reasonable information regarding Diversified Payday's privacy and security practices.

Diversified Payday is not obligated to disclose confidential security information, proprietary information, trade secrets, or information that could increase security risk.

14. Changes in Law

If applicable privacy laws materially change, Diversified Payday may revise this DPA to reflect those legal developments.

15. Liability

Nothing in this DPA expands either party's liability beyond the limitations established in the Terms and Conditions unless applicable law requires otherwise.

16. Order of Precedence

If this DPA conflicts with another Diversified Payday policy regarding Customer Data processing, this DPA controls only with respect to the processing activities addressed herein.

17. Contact

Questions concerning this DPA may be directed to:

Diversified Payday
A Division of Diversified Company
A wholly owned subsidiary of Diversified Universal LLC
6212 US Highway 6, Suite 184
Portage, Indiana 46368-5057
Phone: 833-990-7297
Email: CustomerService@ChooseDiversified.com

Schedule A – Categories of Data

Examples of Customer Data may include:

• Employer information
• Employee information
• Contractor information
• Payroll records
• Wage information
• Tax information
• Banking information
• Benefit information
• User account information
• Support communications

Schedule B – Processing Activities

Processing activities may include:

• Payroll calculation
• Payroll reporting
• Tax preparation
• Tax filing support
• Workforce administration
• Account management
• Customer support
• Fraud prevention
• Security monitoring
• Legal compliance
• Service improvement
• Record retention