UK and Swiss International Transfer Addendum

This page describes how Excalidraw ensures appropriate safeguards for international transfers of Personal Data subject to United Kingdom and Swiss Data Protection Laws.

This Addendum forms part of the Excalidraw Data Processing Agreement (“DPA”) and applies together with the Standard Contractual Clauses (“SCCs”) referenced in the DPA.

United Kingdom

For transfers of Personal Data subject to the UK GDPR, Excalidraw relies on:

• the EU Standard Contractual Clauses adopted under Commission Implementing Decision (EU) 2021/914 (Module 2 – Controller to Processor), and
• the UK International Data Transfer Addendum issued by the UK Information Commissioner’s Office (“ICO”).

The UK Addendum is incorporated by reference and applies to the SCCs used by Excalidraw for such transfers.

Switzerland

For transfers of Personal Data subject to Swiss data protection law, the SCCs apply with the modifications required by applicable Swiss law, including:

• references to the GDPR being understood as references to the Swiss Federal Act on Data Protection (FADP), where applicable, and
• references to supervisory authorities being understood as references to the Swiss Federal Data Protection and Information Commissioner (FDPIC).

Order of Precedence

In the event of any conflict between this Addendum, the SCCs, and the DPA, the SCCs shall prevail to the extent required by applicable Data Protection Laws.

Contact

If you have questions about international data transfers or these SCCs, you may contact Excalidraw at: security@excalidraw.com