EU DATA ACT ADDENDUM

Version 1.0. Last updated on 6 November 2025

This EU Data Act Addendum (the “Addendum”) applies to customers established in or using Modular Finance AB’s (“Modular Finance”) data processing services (the “Services”) in the European Union (“Customer”) and governs all Switching Requests (as defined below) made by a Customer pursuant to Regulation (EU) ²⁰²³⁄₂₈₅₄ (the “Data Act”). This Addendum forms part of the agreement entered into between the Customer and Modular Finance in respect of the provision of Services by Modular Finance (the “Agreement”).

Capitalised terms used but not defined herein shall have the meanings ascribed to them in the Data Act.

1. SWITCHING REQUEST

1.1 The Customer shall have the right to, upon request:

(i) Switch (as defined in Article 2(34) of the Data Act) from Modular Finance to a different provider of the same service type or another service;

(ii) Switch to an on-premises ICT infrastructure; or

(iii) erase their Exportable Data (as defined in Article 2(38)) and Digital Assets (as defined in Article 2(32) of the Data Act).

1.2 The Customer may, at any time during a subscription term and with a two (2) month notice period (the “Notice Period”), request a Switch or erasure of its Exportable Data (“Switching Request”).

1.3 A Switching Request shall specify:

(i) the relevant Service(s); and

(ii) whether the Customer intends to Switch to a different service provider, including the necessary details of the new provider if applicable, or to an on-premises ICT infrastructure, or if the Customer does not intend to Switch but only erase its Exportable Data and Digital Assets.

2. SWITCHING ASSISTANCE

2.1 Modular Finance will provide the Customer, and third parties authorised by the Customer, with reasonable assistance in the Switching process. Modular Finance shall reasonably support the Customer’s exit strategy relevant to the Services, including by providing all relevant information to the Customer in connection with the Switching. Modular Finance shall also provide the Customer with information on available procedures for Switching and exporting.

2.2 Modular Finance shall use reasonable efforts to facilitate a timely completion of the Switching within thirty (30) days from the end of the Notice Period (the “Transitional Period”).

2.3 Modular Finance will inform the Customer within fourteen (14) business days of receiving a Switching Request if the Switching is technically unfeasible. Modular Finance shall duly justify the technical unfeasibility and indicate an alternative Transitional Period, which shall not exceed seven (7) months. The Customer shall confirm receipt of such notice within three (3) business days. Service continuity shall be ensured throughout the alternative Transitional Period.

2.4 The Customer shall also have the right to request an extension of the Transitional Period once for a reasonable period considered more appropriate by the Customer, which shall not exceed the term of the Agreement. The Customer must notify Modular Finance of such extension in writing and indicate the alternative Transitional Period.

2.5 The parties, including Modular Finance, the Customer and any new service provider, shall cooperate in good faith to make the Switching process effective, enable a timely transfer of data and maintain the continuity of the Services.

2.6 The fees for the Service(s) set forth in the Agreement shall continue to apply for the duration of the Transitional Period.

3. OTHER OBLIGATIONS OF MODULAR FINANCE

3.1 Modular Finance shall act with due care during the Switching process to maintain business continuity and continue the provision of the Services under the Agreement, and shall ensure that a high level of security is maintained.

3.2 Modular Finance will inform the Customer about any known risks to the continuity in the provision of the Services and/or technical limitations as a result of the Switching.

4. OTHER OBLIGATIONS OF THE CUSTOMER

4.1 The Customer undertakes to take all reasonable measures to achieve effective switching. The Customer undertakes to be responsible for the import and implementation of Exportable Data and Digital Assets in their own systems or in the systems of the new service provider.

4.2 The Customer and any third party authorised by the Customer, including any new service provider, undertake to respect the intellectual property rights and confidentiality of any materials provided by Modular Finance in the Switching process, as well as Modular Finance’s trade secrets. Any disclosure of such information to a third party is subject to Modular Finance’s prior written approval.

4.3 The Customer shall promptly notify Modular Finance on the completion of the Switching.

5. DATA RETRIEVAL AND ERASURE

Modular Finance shall retain the Customer’s data for a period of thirty (30) calendar days after termination of the Transitional Period, for retrieval or erasure by the Customer (the “Retrieval Period”). At the end of the Retrieval Period and provided that the Switching process has been successfully completed, Modular Finance shall erase the Exportable Data and Digital Assets generated by the Customer or related to the Customer directly, except as required to store under applicable law.

6. TERMINATION

6.1 The Agreement shall be considered to be terminated with respect to the relevant Service(s), and the customer shall be notified of the termination, (i) upon the successful completion of the Switching process; or (ii) at the end of the Notice Period, if the Customer does not wish to Switch but erase its Exportable Data and Digital Assets on termination of the Service(s).

6.2 If the Customer does not notify Modular Finance about successful switching or the lack thereof, while Modular Finance has justified grounds to believe that the Switching was successfully completed by the Customer, Modular Finance may send the Customer the request for confirmation whether the successful Switching took place. If the Customer does not confirm successful Switching within thirty (30) working days from such request, it is deemed that the Switching was not successful and the Agreement will not be terminated and will continue on its existing terms.

6.3 For the avoidance of doubt, such termination will not relieve the Customer of its obligations to pay any fees due to Modular Finance for the period prior to the termination date.

6.4 If the termination pursuant to the events listed in 6.1 (i) or (ii) above occurs before the end of the current term of the Agreement, the Customer shall pay an early termination fee equal to the amount of fees that the Customer would have otherwise been obliged to pay to Modular Finance for the remainder of the current term of the Agreement. The Customer shall not be entitled to a refund or a discount for any fees corresponding to the relevant Service(s) terminated before the end of the current term, except to the extent that prepaid fees exceed the early termination fee.

7. NOTICES

7.1 All notices under this Addendum may be sent via e-mail to the e-mail addresses listed in the Agreement. Each party may change its e-mail address for receipt of notice by giving written notice of the change to the other party.

7.2 A notice shall be effective upon receipt and shall be deemed to have been received at the time of sending, provided that receipt shall not occur if the sender receives an automated message indicating that the e-mail has not been delivered to the recipient.

8. MISCELLANEOUS

8.1 In the event of any discrepancy, inconsistency or ambiguity between the provisions of this Addendum and those of the Agreement, the provisions of this Addendum shall prevail.

8.2 Annex A identifies the categories of Exportable Data and Digital Assets that can be transferred, and the categories of data that Modular Finance is not obliged to transfer under the Data Act.

8.3 The infrastructure for Modular Finance’s Services is subject to the jurisdiction of Sweden.

8.4 Modular Finance has adopted technical, organisational and contractual measures to prevent international governmental access to or transfer of non-personal data held in the EU/EEA, where such access or transfer would create a conflict with applicable law.

8.5 This Addendum shall be governed by and construed in accordance with the substantive laws of Sweden.

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Annex A - Exportable Data and Digital Assets

Service	Exportable Data and Digital Assets	Structure and Format	Data Portability and Restrictions
Monitor	CRM Data	Excel	Exportable Data shall, for the avoidance of doubt, not include any of the following: (i) data not directly or indirectly generated or co-generated by the Customer’s use of the Service(s), (ii) assets or data protected by intellectual property rights, or constituting trade secrets, of Modular Finance or third parties, or (iii) data that, if exported, would expose Modular Finance to cybersecurity vulnerabilities.
Strictlog	Activity log Insider lists PDMR lists	Excel	Exportable Data shall, for the avoidance of doubt, not include any of the following: (i) data not directly or indirectly generated or co-generated by the Customer’s use of the Service(s), (ii) assets or data protected by intellectual property rights, or constituting trade secrets, of Modular Finance or third parties, or (iii) data that, if exported, would expose Modular Finance to cybersecurity vulnerabilities.
MFN	Press releases Subscribers Media library Report archive	JSON Excel .PNG, JPEG etc PDF & Excel	Exportable Data shall, for the avoidance of doubt, not include any of the following: (i) data not directly or indirectly generated or co-generated by the Customer’s use of the Service(s), (ii) assets or data protected by intellectual property rights, or constituting trade secrets, of Modular Finance or third parties, or (iii) data that, if exported, would expose Modular Finance to cybersecurity vulnerabilities.
Datablocks	Financial calendar	Excel	Exportable Data shall, for the avoidance of doubt, not include any of the following: (i) data not directly or indirectly generated or co-generated by the Customer’s use of the Service(s), (ii) assets or data protected by intellectual property rights, or constituting trade secrets, of Modular Finance or third parties, or (iii) data that, if exported, would expose Modular Finance to cybersecurity vulnerabilities.
Holdings	n/a	n/a	Exportable Data shall, for the avoidance of doubt, not include any of the following: (i) data not directly or indirectly generated or co-generated by the Customer’s use of the Service(s), (ii) assets or data protected by intellectual property rights, or constituting trade secrets, of Modular Finance or third parties, or (iii) data that, if exported, would expose Modular Finance to cybersecurity vulnerabilities.
Dataflow	n/a	n/a	Exportable Data shall, for the avoidance of doubt, not include any of the following: (i) data not directly or indirectly generated or co-generated by the Customer’s use of the Service(s), (ii) assets or data protected by intellectual property rights, or constituting trade secrets, of Modular Finance or third parties, or (iii) data that, if exported, would expose Modular Finance to cybersecurity vulnerabilities.