Palarena Professional Services Agreement — Clubs

This Agreement is entered into between:

Palarena: the entity operating the Palarena service, identified in the legal notice, hereinafter “Palarena”;

and

the Club: the entity acting for its professional sports activity, including an association or organization authorized in the context of that activity, identified in the Order Form and represented by the person who accepts this Agreement, hereinafter the “Club”.

Palarena and the Club are individually a “Party” and together the “Parties”.

1. Purpose and contractual structure

Palarena provides the Club with:

• online software for managing its activity;
• tools for publishing its facilities, slots, prices and rules;
• an intermediation service allowing players to book the Club’s services;
• technical orchestration of online payments via Stripe Connect;
• the features included in the plan subscribed to in the Order Form.

The Club remains the seller, the provider and the merchant of record of each sports activity. It enters into the booking contract directly with the player. Palarena does not operate the facilities and does not provide the sports services.

The Agreement comprises, in descending order of priority in the event of a contradiction:

1. the Order Form or accepted summary screen;
2. the negotiated special terms signed by the Parties;
3. this main body;
4. Annex 1 “Payment and technical mandate”;
5. Annex 2 “Data protection”;
6. the “Reversibility and exports” annex and the functional documentation expressly incorporated.

The data protection provisions and mandatory rights prevail over any stipulation that would contradict them. The Order Form cannot reduce a mandatory right.

The Club’s terms of sale to players do not modify this Agreement.

This Agreement covers the software and the intermediation provided by Palarena. Availability in a country depends on the features and payment methods actually supported and announced before subscription. The rules applicable to the Club’s sports services remain separate; the choice of French law for this Agreement does not automatically impose French law on them.

2. Professional account and authorizations

The Club designates a representative authorized to bind it and provides accurate information. Professional accounts are assigned to named individuals; shared accounts are prohibited. The Club assigns roles on a need-to-know basis, enables strong authentication where it is offered and revokes without delay the access of people who leave its teams.

The Club is liable for the actions performed with its accounts, except in the event of a failure attributable to Palarena or proof of a compromise reported promptly despite reasonable measures.

3. Right to use the software

Subject to payment of the sums due, Palarena grants the Club, for the term of the Agreement, a non-exclusive, non-assignable right, limited to its professional needs, to access the software and to use it in accordance with the documentation.

The Club must not:

• copy, resell or make the service available to an unauthorized third party;
• attempt to access the source code or circumvent a security measure, except under a mandatory right;
• extract in bulk the data of Palarena or of other Clubs;
• use the service for an activity that is unlawful, misleading or infringes the rights of others;
• carry out security tests without prior written authorization.

4. Obligations of the selling Club

Before any publication and throughout the period of sale, the Club:

• keeps its legal identity, contact details, registrations and tax information accurate;
• holds the authorizations, qualifications, insurance and means necessary for its activity;
• verifies the qualification and good character (honorabilité) of coaches where regulations so require;
• keeps its facilities and equipment in a compliant and safe condition;
• complies with the information, display and declaration obligations applicable to sports establishments;
• complies with local consumer dispute resolution obligations and indicates the competent mediator or body where an applicable provision or its commitment so requires;
• describes its offers, facilities, accessibility and equipment fairly;
• displays an accurate total price including all taxes before the order;
• configures a complete cancellation, lateness and no-show policy;
• provides the player with its terms of sale and its internal rules;
• performs confirmed bookings and handles complaints within a reasonable time;
• uses players’ data only for lawful and announced purposes;
• holds the necessary rights in the texts, trademarks, photographs and content published.

The Club immediately informs Palarena of a security incident, a closure, an administrative suspension, a loss of insurance, a professional ban or any circumstance making its offer unlawful or dangerous.

5. Publication of offers and formation of bookings

The Club decides on the services offered, the prices, the availability and the commercial rules. Palarena may impose fields and checks necessary for compliance, quality of service or payment.

Palarena renders the booking terms in the Club’s name from the template available for the territory concerned and from the information provided. The Club confirms its legal information, the applicable dispute resolution arrangements, its rules and each version before publication. Publication by the owner is neither a certification nor a second legal validation by Palarena. This technical making-available does not transfer the status of seller to Palarena.

The Club authorizes Palarena to present its offers, receive requests, confirm bookings according to the configured rules, keep the evidence and transmit the necessary transactional communications.

A confirmed booking keeps its price, its cancellation policy and its essential characteristics, even if the Club subsequently changes its configuration for future sales.

6. Listing and ranking

The Club’s eligibility requires an active right of access, a complete Club page, compliance with the Agreement and, for online payments, an operational Stripe account.

The main ranking parameters and any influence of remuneration are described on the public “How the intermediation service works” page. In V1, the plan level does not make it possible to buy a better position, no sponsored offer is available and no referral commission is charged.

The Club authorizes Palarena to use its name, its trademarks and its content to the extent necessary for its listing, the performance of bookings and the internal promotion of its offer within Palarena. Any external advertising campaign mainly using the Club’s identity requires its agreement, except for a mere factual mention of the availability of the service.

7. SaaS subscription

Offer, price and renewal

The Order Form locks in the included features, the price excluding taxes, the taxes, the currency, the billing frequency, the dates and any promotion. The launch offer is invoiced in euros (EUR) and has a single feature tier: €149 excl. VAT per month or €1,490 excl. VAT per year, paid annually. The annual amount is €298 excl. VAT less than twelve monthly payments. No equivalent monthly price replaces the annual total to be paid. The currency of this SaaS subscription does not determine that of the Club’s sports services, which is indicated separately before each order.

The subscription is renewed automatically according to the chosen billing frequency, unless terminated. Stripe Billing processes its payments on behalf of Palarena, separately from the Club’s sports sales. The Club authorizes the debits for the accepted payment dates and maintains a valid payment method. Invoices and the payment method are accessible from the billing portal.

A new list price applies to new subscriptions. The price excluding taxes subscribed to by a Club is kept at the renewals of this subscription, for as long as the Club maintains it without a change of plan or interruption. A new subscription after termination is subject to the price then offered. A statutory change in taxes does not constitute a change in the price excluding taxes. No change of plan is imposed automatically.

First subscription and the Club’s payment account

The first subscription is opened after verification that the Club’s Stripe account is operational for the necessary payments and payouts. Opening an account or sending documents to Stripe does not on its own trigger the subscription. The final summary indicates the start of access, the first payment date and the amount to be paid.

After subscription, a new request for supporting documents by Stripe does not terminate the subscription and does not reset its schedule. As long as the required capabilities remain active, this request does not interrupt operations. If Stripe actually restricts a capability, the new operations concerned may be blocked; the Club is informed and takes the required steps with Stripe. Access to information, to supporting documents and to the tracking of existing operations remains available within the limits necessary for their security. The Club’s rights in the event of non-performance attributable to Palarena remain applicable.

The first subscription also requires seller information published by the owner and an up-to-date venue address, as well as the general approval of the Club and its activation. Subscribing constitutes neither an automatic legal validation of the Club nor a guarantee that its activities will be accepted by Stripe.

Promotion by code

Where a valid code is offered and accepted before subscription, it may grant 90 days without invoicing of the SaaS subscription, on a monthly or annual plan. This period is counted from the start of the trial indicated in the confirmation; it may differ from three calendar months. The code is not applied automatically and is not retroactive. Its validity dates and eligibility criteria are presented before validation. The launch code can be used once per Club; it pays for neither the Club’s sports sales nor its Stripe fees.

The summary displays the date and amount of the first payment after the trial, then the chosen renewal. The Club may request termination during the trial to prevent this first paid renewal, according to the payment date displayed. The free period does not impose a new subscription when it ends if the Club has terminated in time.

Past-due payment and end of period

The Club terminates from the portal. Except for a legal right or non-performance giving rise to restitution, ordinary termination takes effect at the end of the current period, without a pro rata refund of a paid period. The confirmation indicates its effective date.

In the event of a past-due payment, any grace period is indicated in the Order Form and the notifications. The Club may lose its right to publish and to take new bookings when this period expires. Earlier bookings, refunds, complaints, invoices and evidence continue to be handled; delisting does not cancel them. A request to switch providers also falls under Article 11 and the Reversibility annex.

Early end in the context of reversibility

The completed migration or the request for erasure with end of service may end the Agreement before its term under the Reversibility annex. The switching operations and the retrieval of data are free of charge. Their performance is not conditional on the settlement of a contested statement.

For a monthly period paid in advance, the price is retained pro rata to the days of service provided up to that end; the balance is refunded. For an annual period paid in advance, the reduction linked to the annual commitment is recovered only on the duration already provided: that duration is valued at the reference monthly rate locked in by the Order Form of the annual subscription, up to the limit of the annual price for that period. Neither a flat exit fee nor an additional penalty invoice is added. This reference rate is kept, like the annual price, at the renewals of the maintained subscription; a list price increase does not replace it.

The annual calculation is as follows: amount retained = the minimum of A and (12 × M × d / D), rounded to the cent; the refund is A − amount retained. A is the annual price excl. VAT paid for the current period, M its reference monthly rate excl. VAT, D the actual number of calendar days in this paid annual period, and d the number of days of service provided in this period up to the effective end, between 0 and D. Days are counted from date to date; a free trial period does not enter into this calculation and never becomes paid because of the exit. Earlier completed annual periods are not recalculated.

At the launch rate, an end exactly halfway through the paid annual period results in retaining €894 excl. VAT out of €1,490 excl. VAT and refunding €596 excl. VAT. The exact dates determine the calculation; six calendar months do not always represent half the days of the year.

The limited recovery of the discount is the only particular economic consequence of this early end. It does not apply where the end results from non-performance attributable to Palarena or where a mandatory right requires a different refund. It remains subject to the applicable rules of proportionality and powers of the court. The statement distinguishes the service provided, the discount recovered and the balance; taxes and supporting documents are adjusted according to their applicable regime. The balance due to the Club is returned within thirty days of the effective end, without waiting for the close of a dispute relating only to another amount.

8. Fees on the Club’s sales

The price including all taxes accepted by the player goes to the Club, less the fees that Stripe charges it under its own agreement. The Club has a Stripe account with access to its full dashboard. Palarena does not set Stripe’s fees and does not present them as a guaranteed Palarena rate.

At launch, Palarena charges no commission on the bookings, passes or memberships sold by the Club to players, and no service fee to players. No per-payment Palarena flat processing fee is added to the SaaS subscription. Private collections, recorded at the front desk or on-site do not give rise to a Palarena commission.

A technical capability that makes it possible to define a commission does not constitute an accepted rate. Any future offer involving a commission must be the subject of a clear contractual rate, accepted or modified under the applicable legal mechanism, and of information on its basis, its taxes, its exemptions and its refund before activation. The commercial terms of an operation are locked in; a later change does not apply retroactively to that operation.

9. Invoicing, taxes and declarations

The Club is responsible for determining the price and the tax treatment of the service sold to the player. It issues the supporting document or the invoice to the player where this is required. Palarena may generate or transmit this document in the name and on behalf of the Club according to the settings entered, without becoming the seller.

Palarena invoices the Club for the SaaS subscription and only for the other services expressly ordered. The Club provides an accurate billing address and a VAT number or other tax identifier where applicable and necessary. Information intended for invoicing is not published on the Club page without a separate obligation or necessity.

Subscription invoices are payable on the due date stated in the Order Form, with no early-payment discount. For a delay in a professional relationship, penalties accrue from the day after the due date, without a reminder, at the European Central Bank’s refinancing rate applicable to the half-year plus ten percentage points. The fixed recovery charge is €40 per late invoice; additional costs are claimed only on justification and under the legal conditions. The exceptions relating to insolvency proceedings (procédures collectives) remain applicable. None of these B2B charges may be passed on to the player’s payment.

Each Party complies with its accounting, tax and declaration obligations. The Club provides Palarena with the information reasonably necessary for the obligations that may fall on a platform operator, in particular under DAC7, and certifies its accuracy. Palarena informs the Club of the data declared where regulations so require.

10. Service, maintenance and assistance

Palarena uses the reasonable means of a professional to ensure the availability, security and maintenance of the service. Planned operations likely to have a significant impact are announced where possible.

Support is available at contact@palarena.com according to the hours and service levels of the plan. Unless there is a specific written commitment, Palarena does not guarantee uninterrupted availability or a set resolution time.

11. Data, access and export

The Club accesses the offers and data relating to its own customers, bookings, payments and activities. It has no right of access to the player’s activities with other Clubs.

Palarena retains the rights in the software, its structure, its documentation and truly anonymous aggregated data. The Club retains its rights in its content and its own files.

The Club may request the return of its data and a switch of providers under the Reversibility and exports annex, incorporated into this Agreement. It describes the exportable data, formats, time limits, assistance, limits and deletion arrangements. The protection of other users cannot justify a blanket refusal where the Club’s data can be isolated. Statutory retention periods are distinguished from access to the commercial service.

12. Confidentiality

Each Party protects the non-public information received from the other and uses it only for the Agreement. It limits access to it to persons who need to know it and are bound by an obligation of confidentiality.

This obligation does not cover information that has become public without fault, was already lawfully known, was received from an authorized third party or was developed independently. A legally required disclosure is limited to what is necessary and, where permitted, preceded by notice to the other Party.

13. Security

Palarena applies the measures described in Annex 2. The Club secures its workstations, accounts, exports and own systems. Each Party informs the other without undue delay of an incident likely to affect the data or the performance of bookings.

The Club must never request or store full card data via Palarena. Payment transactions use exclusively the interfaces provided.

14. Subcontractors

Palarena may use necessary service providers, in particular Stripe, hosting, email, notifications and security. The list and the change arrangements relating to processing carried out on the Club’s behalf appear in Annex 2 and at https://palarena.com/en/legal/service-providers/2026-09-13/.

15. Liability and insurance

Each Party is liable for the direct damages caused to the other by its proven breach.

The Club is liable in particular for its offers, prices, information, facilities, coaches, content, obligations as seller, treatment of its customers and performance of the services. Palarena is liable for the operation of its own services, its payment instructions and its contractual obligations.

Except in the case of bodily injury, willful misconduct (dol), gross negligence (faute lourde), breach of confidentiality, harm to data attributable to the Party, infringement of intellectual property rights or liability that cannot be limited, a Party’s cumulative liability for a twelve-month period is capped at the amount excl. VAT paid or due to Palarena during the twelve months preceding the event giving rise to liability. This cap cannot be less than the price excl. VAT of one year of subscription under the plan in the Order Form, including during the free trial. This cap does not reduce the Club’s obligation to pay over a sum collected, refund a player or pay an invoice.

Neither Party is liable for indirect damages such as a loss of opportunity or of reputation, unless a mandatory provision provides otherwise.

Each Party maintains insurance suited to its activity and to the territories covered. The Club complies with the coverage and information obligations applicable to its services. Palarena may request a relevant supporting document where a targeted check justifies it; no systematic annual submission and no document expiry amounts, on its own, to a condition of publication or proof of loss of insurance.

16. Restriction and suspension

Palarena may restrict an offer or suspend all or part of the service in the event of a breach, security risk, unlawful content, inaccurate information, loss of insurance or authorization, fraud, past-due payment, Stripe unavailability or legal obligation.

Palarena communicates to the Club, on a durable medium before or at the time of a restriction or suspension, the reasons and the means of contesting it. Urgency may require immediate action but does not, on its own, set aside this statement of reasons. An exemption from giving reasons applies only in the cases provided for by law, in particular a legal prohibition on communicating the elements concerned; the exceptions specific to a total termination are assessed under Article 4 of the P2B Regulation. The measure is limited to what is necessary. A total termination remains subject to the notice and the legal exceptions of Article 17; mere commercial convenience is not an urgency.

The Club may contest at contact@palarena.com. Palarena examines the request free of charge within a reasonable time.

17. Term and termination

The Agreement takes effect upon acceptance and remains applicable for as long as a professional account, a subscription or operations remain active.

The Club may terminate its subscription from the portal; termination takes effect at the end of the current period. Each Party may terminate for a serious breach not remedied within 30 days of formal notice (mise en demeure), subject to the notice applicable to total termination of the intermediation service. Immediate termination occurs only in the legal exceptions; a provisional protective measure may be taken under Article 16.

Where Palarena ends the whole of the intermediation service without urgent fault on the part of the Club, it sends a statement of reasons at least 30 days before it takes effect, in accordance with the rules applicable to online intermediation services. The legal exceptions remain applicable.

The end of the Agreement does not affect the bookings, payments, refunds, invoices, evidence and obligations that arose beforehand. The clauses on confidentiality, data, ownership, liability, payment and disputes survive for as long as they are relevant.

18. Changes to the Agreement

Palarena notifies any change on a durable medium at least 15 days before it comes into force. A longer period is granted where a significant technical or commercial adaptation is necessary.

The Club may terminate before the notice period expires. The exceptions to the notice period are limited to legal or regulatory obligations preventing compliance with it and to unforeseen and imminent dangers, in particular fraud, malware, spam, data breach or other cybersecurity risk. A formal correction cannot be used to change rights without the required notice.

No new pricing applies retroactively to operations whose terms have been locked in or to a period already paid. The keeping of the subscription rate under Article 7 also applies to future renewals.

19. General provisions

The Club may not assign the Agreement without Palarena’s written agreement, except in the case of a universal transfer of assets (transmission universelle de patrimoine) with prior notice and equivalent guarantees. Palarena may assign the Agreement in the context of a restructuring or transfer of its business, provided that this does not reduce the Club’s rights.

The invalidity of one clause does not affect the others. Failure to exercise a right does not amount to a waiver. The Parties are independent; the limited payment mandate of Annex 1 creates neither a joint company nor a general power of representation.

Contractual notices are sent to the account and billing email addresses, with a copy to any address designated in the Order Form.

20. Governing law and jurisdiction

The Agreement is governed by French law. The Parties seek an amicable solution for 30 days from a detailed written notice.

Failing agreement, the dispute falls within the jurisdiction of the court that is competent under the legal rules. No exclusive territorial jurisdiction is imposed by this Agreement, in particular on an association or a non-merchant professional. The search for an amicable solution does not prevent an action that is urgent, protective or intended to preserve a time limit.

Annex 1 — Payment and technical mandate

A.1. Roles and Stripe account

The Club sells and provides the service, is its economic beneficiary and assumes its obligations toward the player. Payments are created directly on the Club’s connected Stripe account. The Club accepts the applicable Stripe terms in the Stripe flow, maintains its identity, its bank details and the required supporting documents, and has the Stripe dashboard provided for its account.

Stripe provides the payment and verification services under its own agreement. In the configuration chosen, Stripe collects its fees from the Club and assumes toward the platform the role of collecting payment losses provided for by its terms; this does not extinguish any debt of the Club to Stripe or its obligation to refund the player. Palarena guarantees neither the validation, nor the payout schedule, nor the continued existence of the Stripe account.

Palarena provides technical orchestration. The SaaS subscription is a separate payment for the benefit of Palarena; the Club’s sports revenue does not pass through a Palarena bank account.

A.2. Limited authorization

The Club authorizes Palarena, for operations carried out via the software, to transmit to Stripe the instructions for preparing the payment method, creation, authorization, capture, cancellation and refund; to receive events; to reconcile operations; to transmit supporting documents; and to apply the commercial rules locked in for each sale.

This authorization covers a commission only if an express rate provides for it under Article 8. It does not permit changing the accepted price, using the funds for another purpose or concluding services outside the agreed flow. It does not entail a general power of representation or the transfer to Palarena of the status of payment service provider.

A.3. Payment dates and saved card

The summary of each order specifies its arrangement: immediate payment or deferred charge. In the latter case, the card may first be prepared and the payment commitment recorded, without immediate authorization. Authorization may be requested as the activity approaches; capture of the price takes place at the start of the activity, subject to cancellation and its announced consequences. A registration for a public activity may remain subject to a separate viability condition.

The agreement to pay for an order and the optional agreement to save the card for future purchases are separate. The authentications requested by the bank remain necessary. An error or a pending bank status does not amount to confirmation of a booking: the final status and the confirmation are authoritative.

A payment failure gives rise to the resolution flow displayed. It may prevent a new booking or lead to the cancellation provided for by the player contract; it does not authorize a charge greater than the accepted commitment.

A.4. Cancellations and refunds

Before capture, the authorization that is not due is released; if a cancellation penalty is validly due, capture remains limited to that penalty. After capture, the refund is executed on the payment of the Club account, to the original payment method. The full refund due to the player cannot be reduced by the Club’s Stripe or Palarena fees.

The Club funds its refunds and disputes under its Stripe agreement. An insufficient balance may delay execution at Stripe, without extinguishing the debt to the player. The Club and Palarena track the actual status of the operation and inform the player; a requested refund is not presented as definitively executed while it is pending or has failed.

If a Palarena commission is activated in a future offer, the corresponding share is returned in proportion to the amount refunded, unless a special term is more favorable. Stripe’s own fees follow Stripe’s rules; Palarena does not promise that Stripe will return them.

A.5. Disputes and Stripe incident

The Club cooperates within Stripe’s time limits and provides the evidence of its service. It bears the consequences relating to its service or its fault under the legal conditions and Stripe’s. Palarena is liable for its own faulty instructions under the Agreement. Refund and dispute operations are coordinated to avoid a double refund.

The suspension of a payment capability affects the new operations concerned. It does not remove the obligations arising from sales already concluded. A mere request for documents that leaves the capabilities active does not on its own cause the termination of the SaaS.

A.6. On-site collection and supporting documents

Where a payment in cash or through the Club’s own terminal is recorded, Palarena records the professional declaration without carrying out that payment at Stripe. The Club is responsible for its collection, its supporting document and its reconciliation. No Palarena payment fee or commission applies to this record.

A payment statement or a Stripe receipt is not automatically a tax invoice for the sports service. The seller remains responsible for the appropriate supporting document.

Annex 2 — Data protection

B.1. Allocation of roles

Palarena acts as controller for the global account, authentication, platform-wide features, platform security, intermediation, favorites, settings and the technical orchestration of payment.

The Club acts as controller for its offers, the provision of sports services, its commercial management, its invoicing, its regulatory obligations and the use of its own customer files.

Palarena acts as the Club’s processor only where it hosts or processes, on the Club’s documented instructions, data specific to the Club’s management space without determining a platform-wide purpose. Articles B.2 to B.11 then constitute the agreement provided for by Article 28 of the GDPR.

If a future feature involves a joint determination of purposes and means, it will be activated only after a joint controllership agreement and after the individuals have been informed.

B.2. Description of the processing carried out on the Club’s behalf

B.3. Instructions

Palarena processes the data processed on the Club’s behalf only on the Club’s documented instructions, consisting of the Agreement, the configuration and the authorized actions. Palarena informs the Club if an instruction appears to it to violate regulations, and may suspend it until clarification.

Palarena may process the data where a law so requires, after informing the Club unless prohibited.

B.4. Confidentiality and access

Palarena limits access to persons who are authorized, trained and bound by confidentiality. Rights are reviewed and withdrawn when they are no longer necessary.

The Club applies the same principles to its users and prohibits exports or consultations without a professional reason.

B.5. Security

Palarena implements technical and organizational measures suited to the risks, covering in particular:

• encryption of communications and appropriate protection of data at rest;
• logical separation of Clubs and server-side authorization checks;
• strong authentication for sensitive roles;
• logging of administrative operations and sensitive access;
• management of secrets, patches and vulnerabilities;
• backups, control of their cycle and verification of the ability to restore;
• protection against enumeration, bulk extraction and abuse;
• incident procedure and proportionate continuity.

The documented description of the measures actually deployed and of their verifications is kept available to the Club. No certification or guaranteed availability is implied. The measures may change without substantially reducing the agreed level of protection.

B.6. Subprocessors

The Club gives general authorization for the subprocessors listed at https://palarena.com/en/legal/service-providers/2026-09-13/. Palarena notifies the addition or replacement of a subprocessor at least 15 days before the start of the processing concerned. A justified urgency may lead to agreeing on a shorter notice period, but removes neither the prior information nor an effective possibility of objection. If these guarantees cannot be ensured, the Club’s prior specific authorization is obtained before the new processing.

The Club may raise a reasoned objection related to data protection. The Parties seek a reasonable solution; failing that, the Club may terminate the affected feature. Palarena imposes substantially equivalent obligations on the subprocessor and remains responsible for its obligations as processor.

B.7. International transfers

Transfers outside the European Economic Area also include access to and the return of data to a Club established in a third country; they are not limited to technical service providers. The Parties identify the data flows and their respective roles before the processing concerned. They put in place a valid mechanism: an adequacy decision within its exact scope or appropriate safeguards, in particular standard contractual clauses suited to the roles, with an analysis and additional measures where necessary. Mere acceptance of this Agreement does not constitute these safeguards.

An adequacy decision does not cover all the entities of a country without distinction: in Canada, its scope covers commercial organizations subject to the federal legislation concerned; in the United States, the Data Privacy Framework requires in particular a participating recipient whose certification covers the processing. The mechanism applicable to the actual recipient is documented.

Where a Club is subject to Quebec rules requiring a privacy impact assessment before entrusting processing outside Quebec, it carries out that assessment. Palarena provides the relevant technical information and the Parties document the written agreement and the required measures. These provisions do not constitute an announcement that the service is opening in those territories.

B.8. Assistance

Taking into account the nature of the processing, Palarena reasonably assists the Club in:

• responding to requests to exercise rights;
• securing the data;
• notifying a breach;
• carrying out an impact assessment or prior consultation.

If Palarena receives a request relating exclusively to the Club’s own data, it forwards it to the Club without responding on the substance, unless instructed or legally required to do so. Manifestly excessive requests outside the standard service may be invoiced after agreement.

B.9. Data breaches

Palarena notifies the Club of a breach of data processed on the Club’s behalf without undue delay after becoming aware of it. It communicates the available information progressively: nature, categories and approximate volume, likely consequences, measures taken and contact.

The Club remains responsible for notifying the authority and the individuals for the processing of which it is the controller. Palarena communicates publicly on behalf of the Club only with its agreement or under a legal obligation.

B.10. Fate of the data

At the end of the service, Palarena allows export during the contractual period and then, at the Club’s choice and subject to legal obligations, deletes or returns the data processed on the Club’s behalf. Backup copies are purged according to the documented cycle and remain isolated until deletion.

The data that Palarena must keep as controller, in particular evidence, security, platform-wide operations or legal obligations, is not covered by the Club’s deletion instruction.

B.11. Information and audit

Palarena provides the information reasonably necessary to demonstrate compliance with this annex. In ordinary circumstances, the Parties organize an annual documentary audit with 30 days’ notice, during business hours, without access to the data of other customers or to secrets that would compromise security.

The frequency, notice and method of audit are adapted where the information is insufficient, in the event of reasonable grounds of non-compliance, an incident or a request from an authority; they cannot prevent the verifications required by Article 28 of the GDPR. An on-site audit is organized where necessary. Its costs are borne by the Club, except in the event of substantial non-compliance by Palarena.