DATA PROCESSING AGREEMENT​

Document Version: 1.4

Date: February 2026

This Data Processing Agreement ("Agreement") forms part of the Contract for Services ("Principal Agreement") between:

<Customer name and address> (the "Customer")

and

Weaviate B.V. Prinsengracht 769A, 1017JZ Amsterdam, The Netherlands, (the "Data Processor")

(together as the "Parties").

WHEREAS

• The Customer acts as a Data Controller.
• The Customer wishes to use Weaviate's services, which involve the processing of Company Personal Data.
• The Parties agree to this Data Processing Agreement that complies with the requirements of the current legal framework in relation to data processing and with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation or GDPR).
• For the purposes of this Agreement, the Customer acts as a Processor on behalf of a Controller, and the Data Processor acts as a Subprocessor within the meaning of Article 28 of Regulation (EU) 2016/679 (GDPR).
• The Parties set out their rights and obligations.
  

IT IS AGREED AS FOLLOWS:

1. Definitions​

1. The following terms, when used in this Agreement will have the following meanings:

   • "Agreement" means this Data Processing Agreement and all Schedules;
   • "Contracted Processor" means a Subprocessor;
   • "Company Personal Data" means Personal Data processed by Data Processor as instructed by the Customer, where the Personal Data is uploaded or provided to the Weaviate database service by the Customer;
   • "Data Controller Personal Data" means any Personal Data Processed by a Contracted Processor on behalf of the Data Controller pursuant to or in connection with the Principal Agreement;
   • "Data Protection Laws" means EU Data Protection Laws and, to the extent applicable, the data protection or privacy laws of any other country;
   • "Data Transfer" means: (A) a transfer of Data Controller Personal Data from the Data Controller to a Contracted Processor; or (B) an onward transfer of Data Controller Personal Data from a Contracted Processor to a Subcontracted Processor, or between two establishments of a Contracted Processor, in each case, where such transfer would be prohibited by Data Protection Laws (or by the terms of data transfer agreements put in place to address the data transfer restrictions of Data Protection Laws);
   • "EU Data Protection Laws" means EU Directive 95/46/EC, as transposed into domestic legislation of each Member State and as amended, replaced or superseded from time to time, including by the GDPR and laws implementing or supplementing the GDPR;
   • "GDPR" means EU General Data Protection Regulation 2016/679;
   • "Services" means the Weaviate Cloud Services that Weaviate provides to the Customer.
   • "Subprocessor" means any person appointed by or on behalf of the Data Processor to process Personal Data on behalf of the Customer in connection with the Agreement.

2. The terms "Controller", "Data Subject", "Member State", "Personal Data", "Personal Data Breach" and "Processing" shall have the same meaning as in the GDPR, and their cognate terms shall be construed accordingly.

2. Processing of Company Personal Data​

Data Processor shall:

1. comply with all applicable Data Protection Laws in the Processing of Company Personal Data;
2. not process Company Personal Data other than on the relevant Customer's documented instructions issued in writing (including processing related to model training).
3. Inform the customer if it is believed that an instruction violates data protection laws; and
4. Suspend execution of a potentially unlawful instruction pending confirmation from Customer.

3. Data Processor Personnel​

Data Processor shall take reasonable steps to ensure the reliability of any employee, agent or contractor of any Contracted Processor who may have access to the Company Personal Data, ensuring in each case that access is strictly limited to those individuals who have received appropriate data protection training, a need to know / access the relevant Company Personal Data, as strictly necessary for the purposes of the Principal Agreement, and to comply with Applicable Laws in the context of that individual's duties to the Contracted Processor, ensuring that all such individuals are subject to confidentiality undertakings or professional or statutory obligations of confidentiality.

4. Security​

1. Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of Processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, Data Processor shall in relation to the Company Personal Data implement appropriate technical and organizational measures to ensure a level of security appropriate to that risk, including, as appropriate, the measures referred to in Article 32(1) of the GDPR.
2. In assessing the appropriate level of security, the Data Processor shall take account in particular of the risks that are presented by Processing, in particular from a Personal Data Breach.
   

5. Subprocessing​

1. The Data Processor shall not engage, appoint, or disclose any Company Personal Data to any Subprocessor without informing the Customer at least 30 days prior to any intended addition or replacement via the website at https://weaviate.io/subprocessors. The Customer, upon being informed, may object to the appointment of that Subprocessor within 30 days on reasonable data protection grounds. Data Processor will at its discretion allow the customer to terminate the contract, or continue the contract without the use of the new/replacement Subprocessor.
2. The Customer accepts that the Data Processor will engage subprocessors in connection with this service, as detailed at https://weaviate.io/subprocessors. The Data Processor shall impose the same data protection obligations on each subprocessor by way of a written contract.
3. Notwithstanding the above, the Data Processor agrees not to change the customer-selected cloud provider or hosting region without the customer's written consent.

6. Data Subject Rights​

1. Taking into account the nature of the Processing, Data Processor shall assist the Customer by implementing appropriate technical and organizational measures, insofar as this is possible, for the fulfillment of the Customer obligations, as reasonably understood by Customer, to respond to requests to exercise Data Subject rights under the Data Protection Laws.
2. Data Processor shall:
   1. promptly notify Customer if it receives a request from a Data Subject under any Data Protection Law in respect of Company Personal Data; and
   2. ensure that it does not respond to that request except on the documented instructions of Customer or as required by Applicable Laws to which the Data Processor is subject, in which case Data Processor shall to the extent permitted by Applicable Laws inform Customer of that legal requirement before the Contracted Processor responds to the request.
      

7. Personal Data Breach​

1. Data Processor shall notify Customer without undue delay upon Data Processor becoming aware of a Personal Data Breach affecting Company Personal Data, providing Customer with sufficient information to allow the Customer to meet any obligations to report or inform Data Subjects of the Personal Data Breach under the Data Protection Laws.
2. Data Processor shall cooperate with the Customer and take reasonable commercial steps as directed by Customer to assist in the investigation, mitigation and remediation of each such Personal Data Breach.
   

8. Data Protection Impact Assessment and Prior Consultation​

Processor shall provide reasonable assistance to the Company with any data protection impact assessments, and prior consultations with Supervising Authorities or other competent data privacy authorities, which Company reasonably considers to be required by article 35 or 36 of the GDPR or equivalent provisions of any other Data Protection Law, in each case solely in relation to Processing of Company Personal Data by, and taking into account the nature of the Processing and information available to, the Contracted Processors.

9. Deletion or Return of Company Personal Data​

Subject to this section 9, Data Processor shall promptly and in any event within 30 days of the date of cessation of any Services involving the Processing of Company Personal Data (the "Cessation Date"), delete and procure the deletion of all copies of those Company Personal Data. The Data Processor shall ensure that this deletion obligation extends to all Subprocessors. Upon Customer's request, the Data Processor shall provide written confirmation of deletion. As an alternative to deletion, Customer may request the return of Company Personal Data in a commonly used, machine-readable format.

10. Audits​

1. The Data Processor shall make available to the Customer all information reasonably necessary to demonstrate compliance with its obligations under this Agreement and Article 28 of Regulation (EU) 2016/679 (GDPR), and shall allow for and contribute to audits, including inspections, conducted by the Controller or an auditor mandated by the Controller.
2. Compliance may, in the first instance, be demonstrated through written responses to questionnaires, provision of relevant policies and procedures, and the provision of independent third-party audit reports or certifications. Such document-based audits shall be provided at no additional cost to the Customer.
3. Any on-site audits or audits requiring material bespoke effort by the Processor shall be subject to reasonable advance written notice, shall be conducted during normal business hours, and shall be subject to the Processor's reasonable cost recovery. The Parties shall cooperate in good faith to agree the scope, timing, and conditions of any such audit so as to minimise disruption to the Processor's business and to maintain confidentiality and security. Audits shall be limited to information and systems relevant to the processing of Personal Data under this Agreement.
   

11. Data Transfer​

If personal data processed under this Agreement is transferred from a country within the European Economic Area to a country outside the European Economic Area, the Parties shall ensure that the personal data are adequately protected. To achieve this, the Parties shall, unless agreed otherwise, rely on EU approved standard contractual clauses for the transfer of personal data.

12. Customer Obligations​

Customer shall not include, and shall ensure that its users do not include, any Company Personal Data in metadata fields such as organization, cluster, tenant, or collection names, or in any other similar service identifiers. The Customer acknowledges that such metadata is not intended for the storage or processing of Company Personal Data and shall remain responsible for ensuring compliance with this requirement.

13. Governing Law and Jurisdiction​

1. This Agreement shall be governed by and construed in accordance with the laws of the Netherlands, including Regulation (EU) 2016/679 (General Data Protection Regulation). The courts of the Netherlands shall have exclusive jurisdiction over any dispute arising out of or in connection with this Agreement.
2. Any dispute arising in connection with this Agreement, which the Parties will not be able to resolve amicably, will be submitted to the exclusive jurisdiction of the courts of Amsterdam, The Netherlands.
3. Liability arising out of or in connection with this Agreement shall be subject to the limitations and exclusions of liability set out in the Principal Agreement.
   

14. Term and Termination​

1. This Data Processing Agreement shall commence on the Effective Date of the Principal Agreement and shall remain in force for the duration of the Principal Agreement, unless terminated earlier in accordance with this Section.
2. This Data Processing Agreement shall automatically terminate upon the termination or expiration of the Principal Agreement for any reason.
3. This Data Processing Agreement may not be terminated independently of the Principal Agreement and shall have no separate termination rights. Any termination or expiration of the Principal Agreement shall simultaneously and automatically terminate this Data Processing Agreement without further action by either party.
   

15. Severability​

1. If any provision of this Agreement is held to be invalid, unlawful, or unenforceable in whole or in part, such provision shall be deemed modified to the minimum extent necessary to make it valid, lawful, and enforceable.
2. If such modification is not possible, the invalid, unlawful, or unenforceable provision (or part thereof) shall be deemed severed from this Agreement, and the validity, legality, and enforceability of the remaining provisions shall not be affected.
3. In such a case, the Parties shall use reasonable efforts to agree a valid and enforceable replacement provision that, to the greatest extent possible, reflects the original intent and economic effect of the severed provision.
   

IN WITNESS WHEREOF, the duly authorized representatives of each of the parties hereto have executed this Agreement as of the Effective Date.

Annex A - Description of Processing​

1. Subject Matter and Duration of Processing​

The subject matter of the processing is the provision of data storage, indexing, vectorisation, search, and retrieval services by Weaviate to the Customer.

Processing shall take place for the duration of the Agreement, unless otherwise instructed by the Customer in writing, and shall cease upon termination of the Agreement, subject to the data retention provisions set out below.

2. Nature and Purpose of Processing​

Weaviate processes Personal Data solely on documented instructions from the Customer for the following purposes:

• Storing data uploaded by or on behalf of the Customer
• Indexing and retrieving such data in response to Customer queries
• Vectorising data using Weaviate's embedding service
• Transmitting data to third-party services designated by the Customer via Weaviate's query agent for the purpose of generating search or query results

3. Categories of Data Subjects​

The categories of data subjects are determined and controlled by the Customer and may include, without limitation:

• End users
• Customers
• Employees
• Contractors
• Agents
• Other individuals whose Personal Data is included in content uploaded by the Customer

4. Types of Personal Data​

The categories of Personal Data are determined and controlled solely by the Customer.

Weaviate does not require Personal Data for the provision of its services; however, the Customer may upload documents or other content containing Personal Data for storage and search purposes. Such Personal Data may include any Personal Data contained within Customer-uploaded content.

5. Data Retention​

Customer data is retained for the duration of the Agreement unless deleted earlier by the Customer.

Customers may add, modify, or delete data at their discretion using the services. There is no default data retention period applied by Weaviate to Customer data stored in active systems.

Customer data is backed up daily and retained in immutable backup storage for the period specified in the Master Services Agreement. Backup data is not actively processed and is only accessed for disaster recovery or business continuity purposes.

6. Deletion and Return of Data​

Upon termination of the Agreement, or upon written request by the Customer, Weaviate shall delete or return all Personal Data processed on behalf of the Customer, in accordance with the terms of the Agreement and applicable law.

Personal Data contained in backups shall be deleted upon expiry of the applicable backup retention period specified in the Master Services Agreement.

7. International Data Transfers​

Where the processing of Personal Data involves transfers outside the European Economic Area, such transfers shall be made in accordance with applicable data protection laws and subject to appropriate safeguards as set out in the Agreement, including Standard Contractual Clauses where applicable.

8. Technical and Organisational Measures​

Weaviate shall implement appropriate technical and organisational measures to protect Personal Data as required under Article 32 GDPR. The TOM measures are shown below:

1. Information Security Governance​

• Weaviate maintains a formal Information Security Management System (ISMS) certified against ISO 27001, covering governance, risk management, and compliance functions.
• Policies and procedures are reviewed and approved annually by management.
• A Data Protection Officer (DPO) and Information Security Officer oversee GDPR and HIPAA compliance respectively.
• Security awareness and privacy training are provided to all employees annually, with additional targeted training for high-risk roles.
• All personnel must acknowledge compliance with the Code of Conduct and Information Security Policy.

2. Risk Management​

• A formal risk management process identifies, assesses, and mitigates information security risks on at least an annual basis.
• Risk registers and remediation plans are maintained to track corrective actions.
• Data Protection Impact Assessments (DPIAs) are conducted for high-risk processing activities.
• Results of risk assessments inform updates to controls, policies, and the business continuity plan.

3. Access Control​

• Role-Based Access Control (RBAC) is enforced according to the principle of least privilege.
• Multi-Factor Authentication (MFA) is required for all privileged accounts and access to sensitive systems.
• Single Sign-On (SSO) and centralized identity management (Google Workspace, Drata) are used to manage access.
• Access rights are approved, reviewed quarterly, and revoked promptly upon termination.
• All accounts are uniquely identifiable to support accountability and traceability.

4. Cryptographic Measures​

• Encryption at Rest: Customer and sensitive data are encrypted using AES-256 or equivalent standards.
• Encryption in Transit: TLS 1.2+ is enforced for all external and internal communications.
• Encryption keys are managed securely using cloud provider KMS (AWS, GCP, Azure).
• Policies define key rotation, storage, and revocation procedures.

5. Physical and Environmental Security​

• Weaviate relies on cloud data centers (AWS, GCP, Azure), each certified under ISO 27001, SOC 2, and FedRAMP where applicable.
• Access to physical locations is restricted to authorized personnel through biometric controls, video surveillance, and access logs.
• No on-premise customer data storage occurs.

6. System and Network Security​

• Perimeter security includes firewalls, web application firewalls (WAF), intrusion detection/prevention systems, and endpoint protection.
• Network segmentation and security groups limit traffic based on least privilege.
• Infrastructure logging and monitoring detect anomalous activity, with automated alerts via SIEM integration.
• Regular penetration tests and vulnerability scans are performed at least annually by independent assessors.
• Antivirus and EDR software are deployed across all workstations.
• Cloud configurations restrict public access to storage buckets and enforce encryption.

7. Operations and Change Management​

• Change control procedures ensure that all software and infrastructure changes are reviewed, tested, and approved before production deployment.
• GitHub version control and a CI/CD pipeline enforce code integrity, review, and rollback capability.
• Separation of environments (development, staging, production) prevents data leakage.
• Drata compliance automation continuously monitors configuration baselines, policy adherence, and system integrity.

8. Data Governance and Retention​

• Personal data is classified, handled, and retained per the Data Governance Policy.
• Data is retained only as long as necessary: 180 days post-account closure, plus 180 days in backup storage.
• Secure disposal procedures ensure data is permanently deleted or anonymized.
• Records of deletion are maintained for audit purposes.
• Subprocessors must implement equivalent TOMs via contractual commitments and annual audits.

9. Monitoring, Logging, and Incident Detection​

• Centralized logging of system, application, and network activities allows retrospective analysis.
• Continuous monitoring for malware, intrusion attempts, and unauthorized access is in place.
• Logs are tamper-evident and retained per the data retention policy.
• Drata continuously tracks compliance posture across cloud, identity, and endpoint environments.

10. Incident Response and Breach Management​

• A formal Incident Response Plan (IRP) defines roles, escalation paths, and communication requirements.
• A dedicated Incident Response Team (IRT) manages containment, remediation, and post-incident review.
• Breach notification procedures comply with GDPR Articles 33 and 34, including timelines and regulator communication.
• Lessons learned are documented to prevent recurrence.

11. Business Continuity and Disaster Recovery​

• Daily backups of production data are performed and monitored.
• Annual restoration tests verify backup integrity and completeness.
• Data is replicated across multiple cloud availability zones for resilience.
• Annual business continuity and disaster recovery (BC/DR) tests validate readiness.
• Cybersecurity insurance is maintained to mitigate residual risk.

12. Vendor and Subprocessor Management​

• A vendor management program assesses and monitors all subprocessors handling customer and personal data.
• Subprocessors must adhere to Weaviate's security and privacy standards and are audited annually.
• A vendor risk register tracks security posture, SLAs, and compliance certifications.

13. Data Subject Rights and Privacy Management​

• Defined procedures enable Controllers to support access, rectification, erasure, restriction, portability, and objection requests.
• Data subjects may withdraw consent at any time.
• Privacy Policy communicates how personal data is collected, processed, and protected.
• Annual privacy training ensures employee awareness of GDPR and HIPAA obligations.

14. Continuous Improvement​

• Internal and external audits (SOC 2, ISO 27001, GDPR) are conducted annually.
• Nonconformities trigger corrective action plans tracked to resolution.
• Management reviews evaluate ISMS performance, incidents, and audit findings.