# ChainZap Pilot Data Annex

**Version:** v1.1 — Pre-Incorporation\
**Last updated:** 7 October 2026\
**Effective date:** \[TO BE COMPLETED\]

This Pilot Data Annex ("Annex") supplements the applicable ChainZap
Payout Control Pilot Agreement ("Pilot Agreement") where the Pilot
dataset contains personal data or where applicable law otherwise
requires data-processing terms.

If there is a conflict concerning processing of personal data, this
Annex controls over the Pilot Agreement and incorporated Business Terms
for that subject matter.

## 1. Parties and Application

**Service Provider / ChainZap:** \[TO BE COMPLETED\]\
**Customer:** \[TO BE COMPLETED\]

This Annex applies only to personal data processed by ChainZap on behalf
of the Customer for the Pilot.

The Parties' privacy roles are determined by the factual processing
relationship and applicable law. Where ChainZap processes personal data
solely on the Customer's documented instructions for the Pilot, the
Customer acts as controller/business or equivalent role and ChainZap
acts as processor/service provider or equivalent role, to the extent
applicable.

Nothing in this Annex assigns a legal role contrary to the actual
processing activities or applicable law.

## 2. Pilot Data Specification

Before transfer, the Parties will identify the agreed Pilot dataset and
whether it relates to payouts to natural persons.

The Pilot should use the minimum data reasonably necessary for Payout
Control.

The initial standard scope is official USDT/TRON. The minimum execution-check
package and the treatment of missing historical context are specified in the
Pilot Agreement. Sending-wallet data is optional unless sender verification
is agreed. Direct identifiers are not required for the standard workflow.

Expected fields may include:

-   pseudonymous obligation or business reference;
-   wallet address or expected recipient address;
-   expected amount;
-   asset/token;
-   network;
-   execution/attempt reference;
-   transaction hash;
-   provider or wallet-export status;
-   timestamps;
-   other specifically agreed operational fields.

The Customer should not provide names, email addresses, phone numbers,
government identifiers, bank-account details, KYC documents or other
direct identifiers unless they are specifically required for the agreed
Pilot and documented before transfer.

Private keys, seed phrases and transaction-signing credentials must
never be provided.

Pseudonymised data may remain personal data where a natural person can
be identified directly or indirectly.

## 3. Subject Matter, Nature and Purpose

**Subject matter:** historical analysis of an agreed stablecoin payout
workflow.

**Nature of processing:** receipt, storage, validation, normalization,
matching, reconciliation, allocation, analysis, exception detection,
generation of operational states and evidence, analyst-assisted review,
reporting, security and deletion.

**Purpose:** to perform and evaluate the Payout Control Pilot described
in the Pilot Agreement.

ChainZap will not process Pilot personal data for advertising, unrelated
profiling, sale of personal data or cross-customer decision-making.

## 4. Duration

Processing under this Annex begins when ChainZap first receives Pilot
personal data and continues until the data is returned or deleted in
accordance with the Pilot Agreement and this Annex.

Unless otherwise agreed, active copies of Customer-provided Pilot
personal data will be deleted within **30 days** after completion or
termination of the Pilot.

Backups may persist until overwritten in the ordinary backup cycle and
remain subject to this Annex while retained.

## 5. Categories of Data Subjects

Depending on the Customer's workflow, data subjects may include:

-   individual affiliates;
-   creators;
-   contractors;
-   individual merchants;
-   customers or counterparties receiving payouts;
-   Customer personnel whose identifiers appear in operational records.

The Customer will identify any materially different category before
transfer.

## 6. Categories of Personal Data

Depending on the agreed dataset, personal data may include:

-   pseudonymous internal identifiers;
-   blockchain wallet addresses;
-   transaction hashes and associated public blockchain activity;
-   payout amounts, assets and timestamps;
-   execution/attempt references;
-   provider-status information;
-   associations between the above information and a Customer business
    obligation.

Direct identifiers and sensitive/special-category data are outside the
standard Pilot scope unless expressly agreed in writing.

## 7. Customer Instructions

ChainZap will process personal data only:

-   on documented Customer instructions contained in the Pilot
    Agreement, this Annex and agreed data specification;
-   as reasonably necessary to perform and secure the Pilot;
-   where required by applicable law.

If ChainZap reasonably believes an instruction violates applicable
data-protection law, it may suspend the affected processing and notify
the Customer where legally permitted.

The Customer is responsible for the lawfulness of its instructions and
for having an appropriate legal basis to provide the data to ChainZap
for the Pilot.

## 8. Confidentiality

ChainZap will ensure that persons authorized to process Pilot personal
data are subject to appropriate confidentiality obligations.

Customer-specific associations between business obligations and public
blockchain activity remain confidential even where the underlying
blockchain transaction is publicly visible.

## 9. Security

ChainZap will maintain reasonable technical and organisational measures
appropriate to the Pilot data and risks.

Such measures may include, as appropriate:

-   access controls;
-   tenant/environment separation;
-   credential protection;
-   logging and monitoring;
-   minimisation of raw identifiers in logs;
-   secure transfer mechanisms;
-   retention/deletion controls;
-   measures intended to prevent unauthorized disclosure or alteration.

The standard Pilot does not require private keys, seed phrases, signing
credentials or production execution credentials.

No system can guarantee absolute security.

## 10. Security Incidents

ChainZap will notify the Customer without undue delay after becoming
aware of a confirmed security incident materially affecting Pilot
personal data.

The notice will include information reasonably available to ChainZap
that is relevant to the Customer's assessment and response.

ChainZap will reasonably cooperate with the Customer in investigating
and responding to the incident, subject to the agreed Pilot scope and
applicable law.

## 11. Subprocessors

ChainZap may use subprocessors reasonably necessary to provide
infrastructure, security, blockchain/data access or other technical
functions required for the Pilot.

The Customer gives general authorization to engage the subprocessors
listed before transfer. ChainZap will notify the Customer of any
intended addition or replacement before the change takes effect; the
Customer may object on reasonable data-protection grounds, in which case
the Parties will discuss in good faith and either Party may terminate
the affected Pilot processing.

ChainZap will impose on each subprocessor data-protection obligations no
less protective than this Annex and remains liable to the Customer for
each subprocessor's performance of those obligations.

A current list of material subprocessors relevant to the Pilot,
including relevant processing locations where required, will be provided
or referenced before transfer.

## 12. AI Processing

Customer-specific Pilot personal data will not be submitted to an AI
provider for general-purpose model training.

If an AI service is used to process Pilot personal data, ChainZap will
use contractual terms and settings reasonably intended to prevent the
provider from using that data to train general-purpose models, unless
the Customer expressly agrees otherwise.

Where AI is not required for the agreed Pilot workflow, ChainZap may
perform the Pilot without submitting Customer-specific Pilot data to an
AI model.

The current standard payout batch engine does not require Ask ChainZap or an
LLM. Any separately proposed AI processing of Customer-specific Pilot data
must be documented before it begins, including the provider, fields sent,
minimisation measures and applicable data handling.

AI-generated text, if any, does not replace the underlying structured
evidence or operational state.

## 13. Data Subject Requests

Taking into account the nature of the processing, ChainZap will provide
reasonable assistance to the Customer with requests by data subjects to
exercise applicable privacy rights, where the Customer cannot reasonably
fulfil the request without ChainZap's assistance.

ChainZap will not independently respond to a data subject on the
Customer's behalf unless instructed or legally required.

## 14. Regulatory and Compliance Assistance

Taking into account the nature of the Pilot and information available to
ChainZap, ChainZap will provide reasonable assistance required by
applicable data-protection law in relation to:

-   security of processing;
-   security incidents;
-   legally required data-protection assessments;
-   regulator enquiries relating to ChainZap's processing for the Pilot.

Any material assistance outside the agreed Pilot scope may be subject to
reasonable additional terms where permitted by law.

## 15. Return and Deletion

At the end of the Pilot, ChainZap will, at the Customer's choice, return
agreed Customer Data or Deliverables and delete active copies of Pilot
personal data, subject only to retention required by applicable law.

Unless otherwise agreed, active copies of Pilot personal data will be
deleted within 30 days after Pilot completion or termination.

ChainZap may retain Pilot personal data only where retention is required
by applicable law, and only for as long as required, subject to this
Annex.

Backups may persist until overwritten in the ordinary backup cycle where
immediate deletion is not technically practicable, provided the retained
data remains protected under this Annex and is not actively processed
except where required by applicable law.

Third-party data may be subject to separate lawful retention
restrictions, which will not expand ChainZap's rights to retain Customer
personal data.

## 16. Audit and Information Rights

ChainZap will make available information reasonably necessary to
demonstrate compliance with this Annex to the extent required by
applicable law.

Where applicable law grants the Customer audit rights, the Parties will
first seek to satisfy those rights through available documentation,
questionnaires, reports or other proportionate evidence.

Any on-site or intrusive audit will be subject to reasonable notice,
confidentiality, security safeguards and scope limitations, except where
a regulator or applicable law requires otherwise.

## 17. International Transfers

The Parties will not rely on this Annex alone where applicable law
requires a specific mechanism for international transfer of personal
data.

Before a transfer requiring additional safeguards begins, the Parties
will implement the legally required transfer mechanism, which may
include applicable standard contractual clauses, addenda or other
recognized safeguards.

The required mechanism depends on the Customer's jurisdiction, the
ChainZap contracting entity, hosting/data locations and applicable law.

## 18. No Cross-Customer Use

Pilot personal data, Customer-specific obligations, attempts,
counterparties, amounts and outcomes will not be disclosed to another
customer or used to make decisions for another customer except under a
separate written agreement with the Customer and where permitted by
applicable law.

On the Customer's instruction given by Section 3 of this Annex, ChainZap
may anonymise Pilot data to generate Service Data as defined in the
Business Terms, including aggregated Pilot metrics, provided that the
resulting information does not relate to an identified or identifiable
natural person and no Customer-specific obligations, counterparties,
amounts or outcomes can reasonably be derived from it.

Once data has been validly anonymised so that it no longer constitutes
personal data under applicable law, use of that anonymised Service Data
remains subject to the Business Terms and applicable confidentiality
obligations.

## 19. Order of Precedence

For personal-data processing covered by this Annex, the order of
precedence is:

1.  any mandatory transfer mechanism or data-protection clause that
    expressly states it prevails;
2.  this Pilot Data Annex;
3.  the Pilot Agreement;
4.  the incorporated ChainZap Business Terms.

## 20. Changes

Any material change to the Pilot processing purpose, categories of
personal data, categories of data subjects or subprocessors that
requires Customer authorization under applicable law will be addressed
before the changed processing begins.

## 21. Signatures

### ChainZap / Service Provider

Legal name: \[TO BE COMPLETED\]\
Name of signatory: \[TO BE COMPLETED\]\
Title/capacity: \[TO BE COMPLETED\]\
Date: \[TO BE COMPLETED\]\
Signature: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

### Customer

Legal name: \[TO BE COMPLETED\]\
Name of signatory: \[TO BE COMPLETED\]\
Title/capacity: \[TO BE COMPLETED\]\
Date: \[TO BE COMPLETED\]\
Signature: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_