Deltek General Privacy Terms

20260901

Prior versions of our privacy terms: 2024, 2023

These Deltek General Privacy Terms (“Privacy Terms” or “Terms”) are incorporated and form a part of the agreement entered into between the Customer and Deltek as well as any other applicable and associated written or electronic agreements such as terms of service and terms of use for the purchase of software and services (“Agreement”).  For purposes of the Privacy Terms, “Deltek” refers to the Deltek entity identified in the applicable Order Form (as defined in the Agreement).  

1. Scope and Structure

1.1. Here at Deltek, we strive to deliver software and information solutions that connect and automate your projects to help you fuel your business. As part of this mission, we want to clearly explain your rights, our obligations, and the protections we provide with respect to personal data you entrust to us. Since many of our customers use different Deltek products and services in different countries around the world, multiple privacy regimes may apply to your data. This section of our Terms explains the scope and structure of these Terms.

1.2. These Terms apply where and only to the extent that Deltek processes Personal Data in the course of providing the Service to the Customer pursuant to the Agreement. Additionally, these Terms do not apply to any Agreement for Deltek’s Information Solutions products and services. For the Information Solutions Privacy Terms, please click here or contact your customer support team member to obtain a copy. References to “Customer Personal Data” in these Terms shall be to all Personal Data that Deltek processes on behalf of the Customer pursuant to the Agreement.  

2. Definitions

Any term not defined in this Section 2 of these Privacy Terms shall have the meaning provided to it in the Agreement.

2.1. "Affiliate" means an entity that directly or indirectly Controls, is Controlled by or is under common Control with either party.

2.2. "Control" means an ownership, voting or similar interest representing fifty percent (50%) or more of the total interests then outstanding of the entity in question. The term "Controlled" will be construed accordingly.

2.3. “Consumer” will have the meaning given it in Section 1798.140(g) of the CCPA and Section 1798.140(i) of the CPRA.

2.4. “Confidential Information” shall have the same meaning as set forth in the underlying Agreement. 

2.5. “Controller” has the meaning given to the terms "controller", "business" or any equivalent term under applicable Privacy Law.

2.6. “Personal Data” means information that relates to an identified or identifiable natural person. For the purpose of the Privacy Terms, Personal Data shall encompass similar terms, which vary based on jurisdiction but govern similar concepts, such as “Personally Identifiable Information” and “Personal Information.” For the avoidance of doubt, “Personal Data” does not include “Aggregated Data.”  

2.7. “Privacy Laws” means legislation, statutory instruments and any other enforceable laws, codes, regulations, or guidelines regulating the collection, use, disclosure and/or free movement of Personal Data that applies to any of the parties, to the Privacy Terms, or to this Agreement, including, in particular: (i) the California Consumer Privacy Act and its implementing regulations, as well as the California Privacy Rights Act, as may be amended from time to time (collectively referred to as “CCPA”); (ii) Canada’s Personal Information Protection and Electronic Documents Act, as may be amended from time to time, and similar provincial implementations, (“PIPEDA”) and any applicable and substantially similar provincial legislation; (iii) the European Union’s (“EU”) General Data Protection Regulation (EU) 2016/679 and any Member State implementing legislation (“EU GDPR”); (iv) the “UK GDPR” as defined in section 3 of the UK Data Protection Act 2018 (the UK GDPR and EU GDPR, together, the “GDPR”); (v) the Swiss Federal Act on Data Protection of 25 September 2020 (“Swiss FADP”); (vi) the Privacy and Electronic Communications Directive 2002/58/EC (as amended by Directive 2009/136/E) in the applicable EU Member State and in the UK; (vii) the Asia-Pacific (“APAC”) intraregional frameworks, in particular the Asia-Pacific Economic Cooperation Cross Border Privacy Rules; and (viii) substantially similar privacy, data protection, or security laws directly applicable to the Processing of Personal Data with respect to providing the Service pursuant to the Agreement.  

2.8. “Process,” “Processed,” or “Processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

2.9. “Processor” has the meaning given to the terms “processor”, “service provider” or any equivalent term under applicable Privacy Law.  

2.10. “Product,” “Products,” “Service,” and “Services” shall have the same meaning as used in the underlying Agreement.

2.11. "Restricted Transfer" means: (i) where the EU GDPR applies to the Processing, a transfer of Personal Data to a recipient in a country outside of the European Economic Area which is not subject to an adequacy determination by the European Commission; (ii) where the Swiss FADP applies to the Processing, a transfer of Personal Data to a recipient in any other country which is not listed as providing an adequate level of data protection in Annex 1 to the Swiss Data Protection Ordinance of 31 August 2022; and (iii) where the UK GDPR applies to the Processing, a transfer of Personal Data to a recipient in any other country which is not listed as providing adequate protection for personal data in Schedule 21 of the UK Data Protection Act 2018 or subject to adequacy regulations pursuant to Section 17A of the United Kingdom Data Protection Act 2018.  

2.12. “Sell” will have the meaning given it in Section 1798.140(ad) of the CPRA.

2.13. "Security Incident" means any breach of security that leads to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of or access to Customer Personal Data.

2.14. “Share” will have the meaning given to it in Section 1798.140(ah) of the CPRA.

2.15. “Special Categories of Personal Data” means the processing of biometric data in the form of photographs by Deltek or its Affiliates for the purpose of fulfilling its obligations with respect to providing the Service pursuant to the Agreement or these Privacy Terms.

2.16. "Sub-processor" means any Processor engaged by Deltek or its Affiliates, subject always to Deltek observing Section 5 (Sub-processing) of these Privacy Terms, to assist in fulfilling its obligations with respect to providing the Service pursuant to the Agreement or these Privacy Terms.

3. Roles of the Parties

3.1. As between Deltek and Customer, Customer or any of its Affiliates is the Controller of Customer Personal Data and, save as set out in the Agreement, Deltek shall process Customer Personal Data only as a Processor acting on behalf of Customer.

3.2. Customer Processing of Customer Personal Data. Customer agrees and undertakes that it will comply with its obligations as a Controller under applicable Privacy Laws in respect of its processing of Customer Personal Data and any processing instructions it issues to Deltek. Customer will ensure that proper procedures and processes, such as ensuring the lawfulness and fairness of Customer Personal Data collection, issuing notice to individuals, and obtaining legally required consents, are complied with prior to the transmittal to and Processing of Customer Personal Data by Deltek. Personal Data should be collected, transferred, and disclosed only in a manner that protects individuals’ privacy while permitting Customer and Deltek to efficiently execute the terms of the Agreement. If Customer fails to comply with these requirements, Customer must immediately notify Deltek.

3.2.1. In the event Customer is subject to additional industry or data specific legal or regulatory restrictions, based on its area of business, jurisdiction in which Customer is based or has Authorized Users, and/or categories of data it collects and maintains, such as data localization or record specific retention requirements, Customer is responsible for notifying Deltek of any and all such restrictions that may impact Deltek’s Processing activities and the parties’ compliance obligations. Deltek cannot be responsible for complying with all relevant restrictions applicable to Customer’s business about which it is not reasonably aware.

3.3. Deltek Processing of Customer Personal Data. Deltek shall treat Customer Personal Data under these Terms as confidential information and will process Customer Personal Data only for the purpose of fulfilling the Agreement and in accordance with Customer’s documented lawful instructions, as set forth in the Agreement and these Terms. Processing outside the scope of these instructions will require prior written agreement between Customer and Deltek with additional instructions for processing.

3.3.1. During the course of providing the products or services set forth in the Agreement, Deltek personnel may need to be given access to Customer Personal Data. Access will only be granted to authorized Deltek personnel to the extent needed to perform their duties and satisfy Deltek’s obligations under the Agreement and in accordance with Customer’s lawful written instructions. Such access typically occurs at the behest and with the consent of the Customer. Authorized Deltek personnel are subject to confidentiality obligations no less stringent than those set forth herein.

3.3.2. In limited circumstances, Deltek may process Special Categories of Personal Data at Customer’s expressed direction. This will occur only when Customer purchases certain products or services and Customer will be notified that Special Categories of Personal Data would be in scope prior to purchasing the products or services.

3.3.3. Other than as expressly permitted by these Terms or by Privacy Laws, Deltek shall not disclose, transfer or otherwise make available Personal Data in exchange for monetary or other valuable consideration to any third parties.

4. Locations of Hosting and International Data Transfers

4.1. Depending on the specific product or service offered under the Agreement, Deltek may offer different locations where Customer Personal Data may be hosted or where support services may be provided from.

4.2. Transfers from the European Economic Area, Switzerland, or the U.K. to Deltek.

4.2.1 Deltek participates in the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Framework as set forth by the U.S. Department of Commerce (collectively, the “DPF”). The relevant governments have determined that data transfers conducted under DPF offer an adequate level of protection under GDPR and are thus an approved data transfer mechanism. All data transfers from relevant jurisdictions under this Agreement will be conducted under the DPF Principles. Deltek’s full Data Privacy Framework Policy is available here.

4.2.2. Standard Contractual Clauses. In the event that the DPF   does not, or ceases to apply to the Restricted Transfer, Deltek and the Customer agree that the Standard Contractual Clauses set out in the European Commission Implementing Decision (EU) 2021/914 of 4 June 2021 for the transfer of personal data to third countries pursuant to the GDPR (“GDPR SCCs”), as may be amended from time to time by the European Commission and as further set out in Exhibit 1, shall, subject to Sections 4.2.3 and 4.2.4, apply to such Restricted Transfers and form part of these Privacy Terms.  

4.2.3  To the extent that the UK GDPR applies to the Customer’s Processing when it makes a Restricted Transfer, the Approved Addendum, being the template Addendum B.1.0 issued by the Information Commissioner’s Office (“ICO”) and laid before Parliament in accordance with s119A of the Data Protection Act 2018 on 2 February 2022, as it is revised under Section 18 of those Mandatory Clauses (“UK Addendum”) shall apply and form part of these Terms with respect to the Restricted Transfer and be deemed completed as follows:  

(a) the Addendum EU SCCs shall refer to the GDPR SCCs set out in Exhibit 1;  

(b) Table 1 of the Approved Addendum shall be completed with the details in Annex I to Exhibit 1;  

(c)  the “Appendix Information” shall refer to the information set out in Annex I and Annex II to Exhibit 1;  

(d) both “Importer” and “Exporter” are selected in Table 4.  

4.2.4.  With respect to Customer Personal Data that is protected by the Swiss FADP (as amended or replaced) the GDPR SCCs set out in Exhibit 1 to these Terms, shall apply to transfers of such Customer Personal Data, except that:  

(a) The competent supervisory authority in respect of such Personal Data shall be Swiss Federal Data Protection and Information Commissioner;    

(b) In Clause 17 and Clause 18 the governing law and jurisdiction shall be the law and courts of Switzerland respectively;    

(c) The references to “Member State(s)” shall be interpreted to refer to Switzerland, and Data Subjects located in Switzerland shall be entitled to exercise and enforce their rights under the EU SCCs in Switzerland; and    

(d) References to GDPR in the GDPR SCCs shall be understood as references to the equivalent article or section of the Swiss FADP.    

4.2.5. If any provision of these Privacy Terms or the Agreement contradicts, directly or indirectly, with the Standard Contractual Clauses, the Standard Contractual Clauses shall prevail.

4.2.6. If a new or modified version of the Standard Contractual Clauses or an alternative mechanism supersedes these Standard Contractual Clauses, such new or modified version of the Standard Contractual Clauses or an alternative mechanism shall be deemed to be incorporated into these Terms.

4.3. Transfers from the Asia-Pacific region to Deltek. Deltek is certified under the Asia-Pacific Economic Cooperation (“APEC”)/Global Privacy Recognition for Processors (“PRP”). This certification provides an approved data transfer mechanism between all participating economies including the U.S., Canada, Japan, Korea, Singapore, Mexico, the Philippines, Taipei, and Australia. The full list of all participating countries is available here.

5. Sub-processing

5.1. Authorized Sub-processors. Subject to the provisions of this section, Customer acknowledges and agrees that, Deltek may engage Sub-processors to process Customer Personal Data. Deltek maintains an up-to-date list of its authorized Sub-processors, available here.

5.2. Sub-processor obligations. Where Deltek authorizes any Sub-processor as described in Section 5.1:

5.2.1. Deltek shall carry out due diligence on the Sub-processor regarding its capability to protect Customer Personal Data;

5.2.2. Deltek will restrict the Sub-processor's access to only the requisite Customer Personal Data necessary to assist Deltek in providing or maintaining the Service, and prohibit the Sub-processor from accessing Customer Personal Data for any other purpose;

5.2.3. Deltek will enter into a written agreement with the Sub-processor imposing data protection terms that require the Sub-processor to protect the Customer Personal Data to the standard required by Privacy Laws and these Terms; and

5.2.4. Deltek will remain responsible for its compliance with the obligations of these Terms and for any acts or omissions of the Sub-processor that cause Deltek to breach any of its obligations under these Terms.

5.3. Sub-processor updates. Deltek will provide Customer with at least 45 days' prior notice via the website identified above as well as in an email to Customer’s primary support contact of any changes to its list of Sub-processors. Customer may object in writing to Deltek’s appointment of a new, or replacement of an old, Sub-processor within 10 calendar days of such notice, provided that such objection is based on reasonable grounds relating to data protection. In such event, the parties will discuss such concerns in good faith with a view to achieving resolution.

6. Security Measures and Security Incident Response

6.1. Security Measures. Deltek has implemented and will maintain reasonable and appropriate technical, administrative, and organizational security measures to protect Customer Personal Data from Security Incidents and to preserve the security and confidentiality of Customer Personal Data (“Security Measures”). For an accounting of Deltek’s applicable technical and organizational security controls, Customer may request a copy of Deltek’s Service Organization Controls (SOC) Report(s) or other relevant documentation through its account administrator or via Deltek’s Trust Center.

6.2. Updates to Security Measures. Customer acknowledges that the Security Measures are subject to technical progress and development and Deltek may update or modify the Security Measures from time to time provided that such updates and modifications do not result in the degradation of the overall security of the Service purchased by the Customer.

6.3. Customer Responsibilities. Notwithstanding the above, Customer agrees that the Customer is responsible for securing its account authentication credentials and taking appropriate steps to securely encrypt or backup Customer Personal Data prior to it being uploaded to the Service and for Customer Personal Data that has been downloaded or transferred from the Service.

6.4. Security Incident Response. Upon becoming aware of a Security Incident, Deltek will notify Customer without undue delay (in any case no later than 72 hours from the time Deltek becomes aware) and will provide information relating to the Security Incident as it becomes known or as is reasonably requested by Customer to the extent practicable under the circumstances. Deltek will also take reasonable steps to mitigate and, where possible, to remedy the effects of, any Security Incident. To the extent required by Privacy Laws, the parties shall ensure that the details of the Security Incident and any subsequent notifications or reports related thereto remain Confidential Information.

7. Other Disclosures of Customer Personal Data

7.1. If Deltek receives a governmental or supervisory authority request to disclose Customer Personal Data subject to a legally enforceable order, Deltek must first (to the extent permitted by applicable law) inform Customer of the legal or regulatory requirement and give Customer, at Customer’s cost and expense, an opportunity to directly and promptly object to or challenge the requirement.

7.1.1. In the event Deltek is not legally permitted to notify Customer, Deltek will, unless prohibited from doing so under applicable law, notify Customer’s applicable supervisory authority, if appropriate, to determine how Deltek may comply with the disclosure request.

7.1.2. In any event, Deltek will seek to minimize the scope of information disclosed in response to a legally enforceable disclosure request to that which is absolutely necessary to meet the disclosure obligation under applicable law.

7.2. In addition to providing products or services in accordance with the Agreement, Deltek may collect and use Aggregated Data relating to the usage and performance of the Services provided to Customer for the primary purpose of testing, troubleshooting, or development purposes. To the extent any data collected by Deltek is Personal Data, Customer acknowledges that Deltek: (a) collects such Personal Data directly from Data Subjects; and (b) Deltek Processes such Personal Data as a Controller for the purposes of the GDPR. 

8. Privacy Rights Requests

8.1. Certain individuals (such as those defined as Data Subjects under the GDPR or as Consumers under CCPA) may have certain rights under applicable Privacy Laws over the Customer Personal Data (“Privacy Rights”). Deltek shall, to the extent legally permitted, promptly notify Customer if Deltek receives a Privacy Rights request related to this Agreement.

8.2. Taking into account the nature of the Processing, Deltek shall assist Customer by appropriate technical and organizational measures, insofar as this is possible, for the fulfilment of Customer’s obligation to respond to a Privacy Rights request to the extent required by Privacy Laws. In addition, in the event Customer does not have the ability to address a Privacy Rights request, Deltek shall, upon Customer’s request, provide Customer with commercially reasonable assistance in responding to such Privacy Rights request to the extent Deltek is legally permitted to do so and as required under Privacy Laws. 

8.3. In the event that Privacy Rights requests become excessive or manifestly unfounded, and therefore exceed what is reasonable under the circumstances, costs arising from Deltek’s assistance supporting Customer’s responsibility to address such Privacy Rights Requests shall be reimbursed by Customer on a time and materials basis.

9. Audits

9.1. Deltek will make available to Customer information necessary to demonstrate compliance with its obligations under these Terms and allow for and contribute to audits conducted by Customer upon Customer’s reasonable written request. Unless required by law, the parties agree that any audits will be conducted no more than once in any twelve (12) month period.

9.2. The parties agree that Deltek may provide the following types of audit reports under Section 9.

9.2.1. SOC 1 or 2 Type I or SOC 1 or 2 Type II Report on Deltek's Description of its Service Provider Systems and on the Suitability of the Design and / or Operating Effectiveness of Its Controls Relevant to Security, Availability, Confidentiality, and Privacy or other similar attestation from a third party (e.g., a FedRAMP attestation or ISO/IEC 27001 certification).

9.2.2. A penetration testing attestation letter from an independent third party;

9.2.3. An executive summary of the independent third party’s penetration test; and

9.2.4. A summary level remediation report.

9.3. If Customer believes that audit reports provided under Section 9 reveal that Deltek does not adequately demonstrate Deltek’s compliance with its obligations under these Terms, the parties will work together in good faith to identify and provide additional evidence to demonstrate Deltek’s compliance with these Terms.

10. California-Specific Privacy Terms

10.1. Use of Personal Data. Deltek does not and shall not: (a) Sell or Share Customer Personal Data; (b) retain, use, transmit, or disclose Customer Personal Data for any purpose, or to any third party, other than for the specific purpose, and to the specific service providers or contractors, expressly specified in the Agreement; or (c) combine or update Customer Personal Data received from, or on behalf of Customer with Personal Data received from another source, unless expressly permitted by applicable law and the terms of the Agreement. Deltek certifies that it understands and will comply with these restrictions.

10.2. Collection of Personal Data. Deltek shall not collect any Customer Personal Data directly from a Consumer unless such collection is (a) authorized by the Agreement and (b) necessary to perform the Services.

10.3. Consumer Rights Requests. As described above, Deltek shall cooperate with Customer in responding to and complying with Privacy Rights requests made pursuant to Privacy Laws.

10.4. Compliance. Deltek shall comply with and provide the same level of protection for Customer Personal Data as required under all directly applicable provisions of the CCPA. In the event that Deltek determines it can no longer meet its obligations under the CCPA, Deltek will promptly notify Customer.

10.5. Remediation. Pursuant to this Agreement, Customer may take reasonable and appropriate steps to ensure that Deltek uses the Customer Personal Data in a manner consistent with Customer’s obligations under the CCPA. Upon notice, Customer may take reasonable and appropriate steps to stop and remediate an unauthorized use of Customer Personal Data by Deltek.

11. Canada-Specific Privacy Terms

To the extent Customer is subject to requirements or restrictions other than those outlined in PIPEDA or local or provincial requirements impacting its use of an organization outside Canada, such as those applicable to certain Canadian public sector entities, Customer is responsible for satisfying any notice and consent requirements, as necessary, to properly facilitate transfers to Deltek entities in foreign jurisdictions.

12. EEA and U.K. Specific Privacy Terms

12.1. Assistance with Controller obligations. Deltek shall reasonably assist Customer in ensuring compliance with its obligations under Articles 32-36 of the GDPR (security of Processing, Security Incident notification, Data Protection Impact Assessments, and prior consultation), or equivalent European Privacy Law obligation, taking into account the nature of the Processing and information available to Processor.

12.2. Maintain records of processing. Deltek shall keep records of all Processing of Customer Personal Data by Deltek pursuant to Article 30 of the GDPR or equivalent European Privacy Law obligation.

13. General

13.1. Limitation of Liability and Indemnification. The limitation of liability and indemnification set forth in the Agreement remain in full force and effect and apply to these Terms and all incorporated materials.

13.2. Use of Cookies. Most Deltek Products and Services may contain cookies. Deltek sets and uses cookies for usage tracking purposes and statistical analysis, in accordance with applicable Privacy Laws. The use of cookies helps Deltek improve the Products by giving Deltek insight into how the Products are being used and the information obtained serves to support application functionality related to the Products and Services as outlined in the Agreement. Customer may request additional information regarding the use of cookies via email to privacy@deltek.com.

13.3. Incidental Collections of Customer Personal Data. As part of providing the Products or Services, there may be circumstances in which Customer’s authorized support contact(s) unintentionally, incidentally, or accidentally discloses data, which may include Personal Data, outside the scope and nature of what is agreed upon and typically transmitted for Processing by Deltek under the Agreement. Customer acknowledges that such disclosure of Personal Data may result in Deltek’s incidental collection and Processing of said Personal Data and agrees that this situation does not constitute a Personal Data Breach or violation of the terms of the Agreement or these Terms.

13.4. Complaints. If Customer reasonably believes that Deltek has breached its obligations under these Terms, Customer must provide an express written statement identifying the specific provisions it alleges Deltek has violated or is currently violating. Deltek has thirty (30) days from receipt of said notice to conduct its investigation into the alleged violation(s) and, if necessary, the parties shall work together, in good faith, to cure any identified or confirmed violation(s) in a timely manner. Notice under this paragraph shall be provided in writing to: Privacy@deltek.com or Deltek - Office of the General Counsel, Attn: Privacy, 2291 Wood Oak Drive Herndon, VA 20171 USA.

13.5. Termination and return/destruction of Personal Data. Upon termination of the Agreement, Deltek shall, at the discretion of Customer, either delete, destroy, or return all Customer Personal Data to Customer and destroy or return existing copies unless otherwise legally prohibited from doing so. For any Customer Personal Data Deltek is required to retain after termination of the Agreement, Deltek will continue to meet the obligations set forth in these Terms and will use it only for the purpose for which it has been kept, such as to meet legal retention requirements.

13.6. Integration. Except for the changes made by these Terms, the Agreement remains unchanged and in full force and effect, including, but not limited to, the mutual indemnities provided by the parties. If there is any conflict between these Terms and the Agreement, these Terms shall prevail to the extent of that conflict.

13.7. Governing Law and Severability. These Terms will be governed by and construed in accordance with governing law and jurisdiction provisions in the Agreement, unless required otherwise by applicable Privacy Laws. The provisions of these Terms are severable. If any phrase, clause or provision is invalid or unenforceable in whole or in part, such invalidity or unenforceability shall affect only such phrase, clause or provision, and the rest of these Terms shall remain in full force and effect.

13.8. Updates and Amendments. In the event of additions to or changes in applicable Privacy Law, the parties shall work in good faith to update these Terms as reasonably necessary to comply with applicable Privacy Law. Such request must be provided in writing to privacy@deltek.com or as otherwise provided in the Agreement.

Exhibit 1

With respect to any transfers referred to in section 4.2.2, the Standard Contractual Clauses shall be completed as follows:

• Module Two (controller to processor) of the SCCs will apply.
• Clause 7 of the Standard Contractual Clauses (Docking Clause) does not apply.
• Option 2 of Clause 9(a) (General written authorization) shall apply, and the time period to be specified is set out in section 5.3 of the Privacy Terms.
• The option in Clause 11(a) of the Standard Contractual Clauses (Independent dispute resolution body) does not apply.
• With regard to Clause 17 of the Standard Contractual Clauses (Governing law), the Parties agree that option 1 will apply and the governing law will be the law of Denmark.
• In Clause 18 of the Standard Contractual Clauses (Choice of forum and jurisdiction), the Parties submit themselves to the jurisdiction of the courts of Denmark.

For the purpose of Annex I and Annex II of the Standard Contractual Clauses, Exhibit 2 to these Privacy Terms contains the specifications regarding the parties, the description of transfer, the competent supervisory authority, and the technical and organisational measures.  

Exhibit 2
Schedule 1 – General Data Protection Regulation Standard Contractual Clauses - Annexes

ANNEX I

A. LIST OF PARTIES

MODULE TWO: Transfer controller to processor

Data exporter(s): [Identity and contact details of the data exporter(s) and, where applicable, of its/their data protection officer and/or representative in the European Union]

1. Name: Customer set forth in the Agreement
   
   Address: Details set forth in the Agreement
   
   Activities relevant to the data transferred under these Clauses: Utilizing the Products and Services as set forth in the Agreement
   
   Role (controller/processor): Controller

Data importer(s): [Identity and contact details of the data importer(s), including any contact person with responsibility for data protection]

1. Name: Deltek, Inc. and its subsidiaries and affiliated entities: Deltek Australia PTY Ltd., Deltek GB Limited, Deltek Replicon Software (India) Private Ltd., and Deltek Philippines, LLC.
   
   Address: 2291 Wood Oak Drive, Herndon, VA 20171 U.S.A.

Northpoint Tower, Level 40, 100 Miller Street, North Sydney, NSW 2060, Australia

The Aircraft Factory Cambridge House, 100 Cambridge Grove, London W6 0LE, United Kingdom

2F Wing – B, Salarpuria Supreme Khata NO. 137, Survey NO. 92/5, Munnekolalu Village, Varthur Hobli, Marathahalli, Bangalore

The Enterprise Center, Tower 1, 6676 Ayala Ave., 6th Floor, Makati City, Philippines

Contact person’s name, position and contact details: Cathy Lee, Corporate Counsel – Privacy and Security, privacy@deltek.com

Activities relevant to the data transferred under these Clauses: Providing Products and Services as set forth in the Agreement

Role (controller/processor): Processor

(The parties acknowledge that their respective signatures under the Agreement apply to this Annex I)

B. DESCRIPTION OF TRANSFER

MODULE TWO: Transfer controller to processor

Categories of data subjects whose personal data is transferred:

Customer (as controller) may submit Personal Data to Deltek in the course of its use of the Products and/or Services, including support services, the extent of which is determined and controlled by controller in its sole discretion and may include, but is not limited to, Personal Data relating to the following categories of Data Subjects:

• Prospects, customers, business partners, and vendors and their respective points of contact;
• Employees, contractors, and vendors of data exporter; and/or
• Users authorized by controller to use the Products and/or Services.

Categories of Personal Data transferred:

The Personal Data transferred concern the following categories of data (please specify):

• First and last name
• Title
• Position
• Employer
• Contact information
• Unique identifying data (e.g., government identification numbers, Social Security Numbers, driver’s license number, etc.)
• Professional life data (e.g., job qualifications, employment references, certifications, etc.)

Sensitive data transferred (if applicable) and applied restrictions or safeguards that fully take into consideration the nature of the data and the risks involved, such as for instance strict purpose limitation, access restrictions (including access only for staff having followed specialised training), keeping a record of access to the data, restrictions for onward transfers or additional security measures:

Controller has the capability to insert data elements at their discretion and based on their use of the Products and/or Services. To the extent determined and at the sole discretion of the controller, controller may choose to submit, and thereby explicitly expose Deltek to, special categories of data, subject to the capabilities of the Products and/or Services. For the sake of clarity, any additional Personal Data, including special categories of data as defined under the GDPR, may only be processed and/or accessed by Deltek as necessary during the provisioning of support services.

The frequency of the transfer (e.g. whether the data is transferred on a one-off or continuous basis):

Based on the nature of the Products and/or Services in accordance with the terms of the Agreement.

Nature of the processing: To provide the Product(s) and/or Service(s) as set forth in the Agreement

Purpose(s) of the data transfer and further processing: To provide the Product(s) and/or Service(s) as set forth in the Agreement

The period for which the personal data will be retained, or, if that is not possible, the criteria used to determine that period: As set forth in the Agreement

For transfers to (sub-) processors, also specify subject matter, nature and duration of the processing: 

Customer has provided general authorization to the use of sub-processors from an agreed list set out here.

Deltek controls access to the infrastructure that stores and processes customer personal data used by Deltek’s SaaS Products. Each of Deltek’s SaaS Products contains multiple servers and services to deliver applications efficiently and effectively. Deltek SaaS products hosted in Amazon Web Service (AWS) are hosted in a primary region while backups are replicated to a secondary geographic region within the AWS Cloud. AWS regions include North America (storage in the US), EU (storage in Ireland and Germany), and ANZ (storage in Australia and Singapore). Deltek SaaS products hosted in Microsoft Azure are hosted in a primary region while backups are replicated to a secondary geographic region within the Azure Cloud. Azure regions include North America (storage in the US), EU (storage in Ireland and the Netherlands), Middle East and Africa (storage in South Africa and the UAE), Asia (storage in Hong Kong and Singapore), and Australia (storage in Australia).  Deltek SaaS products hosted in Oracle Cloud Infrastructure (OCI) are hosted in a primary region while backups are replicated to a secondary geographic region within the OCI Cloud.  OCI regions include North America (storage in the US), EU (storage in France and Germany), and ANZ (storage in Australia and Singapore).  

C. COMPETENT SUPERVISORY AUTHORITY

MODULE TWO: Transfer controller to processor

Identify the competent supervisory authority/ies in accordance with Clause 13:

As determined in accordance with Clause 13 of the GDPR SCCs, or otherwise the Danish Data Protection Authority (Datatilsynet).  

ANNEX II

TECHNICAL AND ORGANIZATIONAL MEASURES INCLUDING TECHNICAL AND ORGANIZATIONAL MEASURES TO ENSURE THE SECURITY OF THE DATA

Note: Customers utilizing Costpoint GovCon Cloud Moderate (“GCCM”) may expect the security safeguards in that offering to align with the measures outlined below; however, additional information of compliance with Federal Risk and Authorization Management Program (FedRAMP) Moderate baseline equivalent controls is contained in the Customer Responsibility Matrix (“CRM”), available to GCCM customers upon request.

MODULE TWO: Transfer controller to processor

Description of the technical and organisational measures implemented by the data importer(s) (including any relevant certifications) to ensure an appropriate level of security, taking into account the nature, scope, context and purpose of the processing, and the risks for the rights and freedoms of natural persons are as follows:

Deltek implements and maintains administrative, physical, and technical safeguards for protection of the security, confidentiality, and integrity of Personal Data transferred to and among Deltek affiliates as provided in the Agreement.

For transparency, Deltek makes available current information regarding its Security, Compliance, and Privacy posture on its Security and Trust Center as well as its Trust and Security Portal.

Data Privacy Office

Deltek’s Data Privacy Office can be contacted at privacy@deltek.com. Additional information regarding Deltek’s data protection and handling practices may be located on the Privacy page of the Security and Trust Center.