Terms of Service

Effective Date: July 2026

1. Introduction and Acceptance #

These Terms of Service, together with all documents and policies expressly incorporated by reference (collectively, the “Terms” or this “Agreement”), govern all access to and use of the platform, application programming interfaces, software development kits, documentation, dashboards, and related services (collectively, the “Platform” or the “Services”) made available by Ubiqio Pte. Ltd. and its affiliates (“Ubiqio,” “we,” “us,” or “our”) at ubiqio.com and associated domains.

If you are accepting these Terms on behalf of a company or other legal entity (the “Enterprise,” “Customer,” “you,” or “your”), you represent and warrant that you have the authority to bind that entity, and “you” refers to that entity. Where a separately negotiated master agreement or order form has been executed between you and Ubiqio, that document governs to the extent of any conflict with these Terms.

The Platform is intended solely for business use by Enterprises and their Authorized Users. It is not directed to consumers or to individuals below the age of majority in their jurisdiction.

2. Definitions #

“Authorized User” means an employee, contractor, or agent of the Enterprise whom the Enterprise permits to access the Platform under its account.

“CPaaS Provider” means the third-party communications-platform-as-a-service, carrier, aggregator, or messaging vendor that the Enterprise selects and contracts with directly to originate, transmit, and deliver Communications.

“Communications” means any SMS, MMS, RCS, chat-application messages (such as WhatsApp), voice, email, or other messages or communications that are sent, received, or processed through a CPaaS Provider by means of the Platform.

“Provider Agreement” means the agreement (including any acceptable-use, messaging, and telecom terms) between the Enterprise and a CPaaS Provider governing the Communications and the underlying communications services.

“Unified API” means Ubiqio’s proprietary application programming interface, SDKs, and connectors that provide a single, common integration point through which the Enterprise’s applications connect to one or more CPaaS Providers.

“Message Volume” means the number of Communications processed through, or routed by means of, the Platform during a billing period, measured as described in Section 8.

“Order” means an online or written ordering document, subscription tier selection, or plan through which the Enterprise subscribes to the Services.

“Customer Data” means data, content, and information submitted by or on behalf of the Enterprise to the Platform, including the content and metadata of Communications passed through the Unified API.

“Documentation” means the usage guides, API references, and policies Ubiqio makes available for the Platform.

3. The Ubiqio Platform — What the Service Is #

Ubiqio provides a software abstraction and orchestration layer. The core function of the Platform is to give the Enterprise a single, common Unified API that connects the Enterprise’s applications to the CPaaS Provider of the Enterprise’s choice, so that the Enterprise can build and operate communications applications without integrating separately against each provider.

The Services consist of software, APIs, routing and orchestration logic, dashboards, analytics, and technical support. Ubiqio may make the Services available through ubiqio.com and through other websites, and these Terms apply equally to any rebranded, embedded, or white-label form of the Platform.

The Services may be offered under different features, plans, or availability in different countries or regions, and certain features may not be available in all territories.

4. Relationship With CPaaS Providers #

4.1 Ubiqio is not the carrier or sender of record. #

Ubiqio is a technology intermediary. Ubiqio does not originate, transmit, or deliver Communications, does not operate telecommunications networks, and is not a party to the transmission or delivery of any Communication. Delivery of Communications is performed entirely by the CPaaS Provider and by downstream carriers, networks, and messaging channels outside Ubiqio’s control.

4.2 Direct contract between Enterprise and CPaaS Provider. #

The Enterprise selects and contracts directly with its chosen CPaaS Provider. All rights and obligations relating to the origination, transmission, delivery, pricing, quality, and regulatory treatment of Communications are governed by the Enterprise’s Provider Agreement, not by these Terms. Ubiqio is not a party to, and has no responsibility or liability under, any Provider Agreement.

4.3 Enterprise responsibility for the Provider relationship. #

The Enterprise is solely responsible for: (a) establishing and maintaining an account and any required credentials with each CPaaS Provider; (b) paying all fees, message charges, telecom surcharges, and taxes owed to the CPaaS Provider; (c) complying with the Provider Agreement and all CPaaS Provider and carrier requirements; and (d) completing any registration, onboarding, or provisioning required by the CPaaS Provider or carriers (for example, sender-ID registration, 10DLC / brand-and-campaign registration, short-code provisioning, or channel approvals). Ubiqio may surface, transmit, or assist with such items through the Platform as a convenience, but does not assume responsibility for them.

4.4 No control over provider performance. #

Ubiqio does not warrant and is not responsible for the acts, omissions, availability, latency, throughput, deliverability, pricing changes, suspension, or termination of any CPaaS Provider or carrier, or for any Communication’s final delivery or non-delivery. Ubiqio’s role is limited to correctly processing the Enterprise’s requests and routing them to the applicable CPaaS Provider through the Unified API.

4.5 Provider changes. #

CPaaS Providers may change, deprecate, or discontinue their APIs, features, or services. Ubiqio will use commercially reasonable efforts to maintain its connectors, but is not liable for any resulting disruption, and may add, modify, or remove supported CPaaS Providers over time.

5. Accounts, Credentials, and Security #

To use the Platform, the Enterprise must create an account and provide accurate, current, and complete information. The Enterprise is responsible for maintaining the confidentiality of its account credentials, API keys, and CPaaS Provider credentials stored with or used through the Platform, and is solely responsible for all activity occurring under its account, whether or not authorized.

The Enterprise must promptly notify Ubiqio of any unauthorized use of its account or any suspected security incident. Ubiqio is not liable for any loss arising from unauthorized use of the Enterprise’s account or credentials.

6. Acceptable Use #

The Enterprise’s use of the Platform is governed by the Ubiqio Acceptable Use Policy set out in Part II of this document, which is incorporated into these Terms by reference. Violation of the Acceptable Use Policy is a material breach of these Terms.

7. Compliance and Consent #

7.1 Consent and opt-out. #

The Enterprise represents and warrants that, for every Communication initiated through the Platform, it has obtained all consents, opt-ins, and authorizations required by applicable law and by the recipient’s channel and jurisdiction; that it honors opt-out and revocation requests; and that its use complies with all applicable messaging, telemarketing, privacy, and consumer-protection laws and with all applicable carrier and channel requirements.

7.2 Sole responsibility for content and recipients. #

As between the parties, the Enterprise is solely responsible for the content of its Communications and for its selection of recipients, and for ensuring that its Communications comply with the Provider Agreement and all applicable law.

7.3 Proof of compliance. #

Ubiqio may, at any time, request that the Enterprise provide evidence of its compliance (such as records of opt-in or consent). If the Enterprise fails to provide such evidence, if Ubiqio or a CPaaS Provider receives a third-party or regulatory complaint, or if Ubiqio reasonably believes the Enterprise’s use is unlawful or violates this Agreement, Ubiqio may suspend the Enterprise’s access to the Platform as described in Section 15.

8. Fees, Volume Tiers, and Prepaid Billing #

8.1 Tiered, volume-based subscription. #

Access to the Platform is sold on a tiered subscription based on Message Volume. Each tier entitles the Enterprise to process up to a stated maximum number of Communications per monthly billing period for a fixed monthly fee — for example, a fixed monthly fee for Message Volume of up to 1,000,000 messages per month — at the tiers, thresholds, and rates set out in the applicable Order or published at ubiqio.com.

8.2 Prepaid billing. #

All fees are prepaid. The Enterprise pays the applicable tier fee in advance of the billing period to which it relates, and the Platform is made available on a prepaid basis. The Enterprise’s ability to process Communications through the Platform is contingent on an active, paid-up subscription tier and a sufficient prepaid balance for the relevant billing period.

8.3 Top-ups and tier changes. #

If the Enterprise’s Message Volume approaches or exceeds its current tier during a billing period, the Enterprise may purchase additional prepaid volume (“Top-Ups”) to continue processing, or upgrade to a higher tier. Top-Ups are prepaid and are consumed within the billing period in which they are purchased unless the Order states otherwise. Ubiqio may pause, throttle, or decline to process Communications once the prepaid tier volume is exhausted and no Top-Up or higher tier is in place, without liability for any resulting non-delivery.

8.4 What Ubiqio fees do and do not cover. #

Ubiqio’s subscription fees and Top-Ups are charged solely for access to and use of the Platform and Unified API. They are separate from and in addition to any amounts the Enterprise owes its CPaaS Provider or carriers for the underlying Communications. Ubiqio does not invoice for, mark up, or collect telecom or message-transmission charges owed under the Provider Agreement unless expressly agreed in writing.

8.5 Metering. #

Message Volume is measured by Ubiqio’s systems based on the Communications processed or routed through the Platform during each billing period, and is counted against the Enterprise’s prepaid tier and any Top-Ups. Ubiqio’s records of Message Volume are, absent manifest error, the authoritative basis for calculating usage. The Enterprise may monitor its usage and remaining prepaid balance through the Platform’s dashboards.

8.6 Taxes. #

Fees are stated in Singapore Dollars (SGD) and are exclusive of taxes. The Enterprise is responsible for all applicable sales, use, VAT, GST, and similar taxes, other than taxes on Ubiqio’s net income.

8.7 Non-refundable; unused volume. #

Except as required by applicable law or expressly stated in an Order, prepaid fees and Top-Ups are non-refundable, including on suspension or termination for cause, and unused Message Volume does not roll over to a subsequent billing period.

8.8 Changes to fees and tiers. #

Ubiqio may change its fees, tiers, and volume thresholds on prospective notice, effective at the start of the next billing period or renewal term, or as otherwise stated in the applicable Order.

9. Customer Data, Privacy, and Data Protection #

9.1 Ownership. #

As between the parties, the Enterprise owns its Customer Data. The Enterprise grants Ubiqio a non-exclusive, worldwide license to host, process, transmit, and display Customer Data solely as necessary to provide and maintain the Services, to route Communications to the applicable CPaaS Provider, and as otherwise permitted in this Agreement.

9.2 Data passes through the Platform. #

The Enterprise acknowledges that the content and metadata of Communications transit the Platform en route to the CPaaS Provider. Once a Communication is handed off to the CPaaS Provider, its handling is governed by the Provider Agreement and the CPaaS Provider’s privacy practices, for which Ubiqio is not responsible.

9.3 Privacy Policy and DPA. #

Ubiqio’s processing of personal data is described in the Ubiqio Privacy Policy at https://www.ubiqio.com/privacy-policy and, where Ubiqio processes personal data on the Enterprise’s behalf, in the Data Processing Addendum set out in Part III of this document, which is incorporated into this Agreement. The Enterprise is responsible for establishing any separate data-processing terms it requires with its CPaaS Provider.

9.4 Retention and deletion. #

Ubiqio may retain, and later delete, Customer Data in accordance with its Documentation, Privacy Policy, and the DPA. Except as required by law or expressly agreed, Ubiqio does not guarantee the long-term retention of Communication content and will not be liable for deletion of Customer Data consistent with its stated practices.

9.5 Aggregated and de-identified data. #

Ubiqio may generate and use aggregated or de-identified data derived from use of the Platform (which does not identify the Enterprise, any individual, or any Communication content) to operate, improve, and secure the Services.

10. Intellectual Property #

10.1 Ubiqio IP. #

Ubiqio and its licensors own all right, title, and interest in and to the Platform, the Unified API, SDKs, connectors, Documentation, and all related intellectual property. Subject to this Agreement and payment of applicable fees, Ubiqio grants the Enterprise a limited, non-exclusive, non-transferable, revocable license to access and use the Platform for its internal business purposes during the term.

10.2 Reservation. #

No rights are granted except as expressly stated. All rights not expressly granted are reserved by Ubiqio. Nothing in this Agreement transfers any Ubiqio trademark, patent, copyright, or trade secret to the Enterprise.

10.3 Feedback. #

If the Enterprise provides suggestions or feedback, Ubiqio may use it without restriction or obligation.

11. Service Availability; No Delivery Warranty #

Ubiqio will use commercially reasonable efforts to make the Platform available, subject to any service-level terms in an applicable Order. The Enterprise acknowledges that the Platform depends on third parties — including CPaaS Providers, carriers, networks, and internet infrastructure — and that the Platform may be unavailable due to maintenance, third-party failures, or events outside Ubiqio’s control.

The Enterprise is responsible for obtaining and maintaining the hardware, software, connectivity, and CPaaS Provider relationships needed to use the Platform.

12. Confidentiality #

Each party may receive confidential information of the other. The receiving party will use the disclosing party’s confidential information only to perform under this Agreement and will protect it with at least reasonable care. This obligation does not apply to information that is public through no fault of the receiving party, independently developed, rightfully received from a third party, or required to be disclosed by law (with notice where permitted).

13. Warranties and Disclaimers #

Each party represents that it has the authority to enter into this Agreement.

14. Limitation of Liability #

14.1 Exclusion of indirect damages. #

14.2 Cap. #

14.3 Provider charges excluded. #

For clarity, Ubiqio’s liability cap is calculated solely on Ubiqio subscription fees and Top-Ups, and excludes any amounts paid by the Enterprise to any CPaaS Provider or carrier. Ubiqio has no liability for any charges, losses, or damages arising under a Provider Agreement.

14.4 #

Some jurisdictions do not allow certain limitations; in those jurisdictions the limitations apply to the fullest extent permitted.

15. Suspension #

Ubiqio may suspend the Enterprise’s access to the Platform, in whole or in part, if: (a) the Enterprise materially breaches this Agreement (including the Acceptable Use Policy or the compliance provisions); (b) the Enterprise’s use poses a security, legal, or operational risk to Ubiqio, a CPaaS Provider, or any third party; (c) required by a CPaaS Provider, carrier, law, or regulator; or (d) the Enterprise’s prepaid balance is exhausted or fees are overdue. Where practicable, Ubiqio will give notice and an opportunity to cure, but may suspend immediately where necessary to prevent harm.

16. Term and Termination #

16.1 Term. #

This Agreement begins when you first accept it or access the Platform and continues for the subscription term set out in the applicable Order, renewing as specified there.

16.2 Termination for cause. #

Either party may terminate for the other’s material, uncured breach after 30 days’ written notice, or immediately if the other party becomes insolvent.

16.3 Effect. #

On termination or expiry, the Enterprise’s license to use the Platform ends and the Enterprise must cease using the Unified API. Accrued fees remain payable and prepaid amounts are treated as set out in Section 8.7. Sections that by their nature should survive (including Definitions and Sections 4, 8, 9, 10, 12, 13, 14, 17, and 18) survive termination. Termination of this Agreement does not affect the Enterprise’s separate Provider Agreement.

17. Changes to These Terms #

Ubiqio may modify these Terms from time to time by posting a revised version at https://www.ubiqio.com/terms-and-conditions or by otherwise notifying the Enterprise. Changes are effective as of the stated effective date. The Enterprise’s continued use of the Platform after changes take effect constitutes acceptance. Where a signed Order or master agreement specifies a different change-notification process, that process controls.

18. General #

18.1 Order of precedence. #

In the event of conflict, the following order of precedence applies: (1) a mutually executed Order or master agreement; (2) these Terms; (3) the Acceptable Use Policy, Data Processing Addendum, and other policies and Documentation incorporated by reference. The Enterprise’s Provider Agreement governs the Communications and the underlying communications services and is independent of this Agreement.

18.2 Governing law and disputes. #

This Agreement is governed by the laws of SINGAPORE without regard to conflict-of-laws rules. The parties submit to the courts of SINGAPORE for the resolution of disputes.

18.3 Assignment. #

The Enterprise may not assign this Agreement without Ubiqio’s prior written consent, except to a successor in a merger or sale of substantially all assets. Ubiqio may assign to an affiliate or successor.

18.4 Force majeure. #

Neither party is liable for delay or failure caused by events beyond its reasonable control, including acts of God, outages, carrier or CPaaS Provider failures, or governmental action.

18.5 Notices; independent contractors. #

Notices must be in writing and sent to the contact addresses on file or specified in the Order. The parties are independent contractors; nothing creates a partnership, agency, or joint venture.

18.6 Entire agreement; severability; waiver. #

This Agreement, together with any Order and incorporated policies, is the entire agreement between the parties on its subject matter and supersedes prior discussions. Purchase orders or other terms issued by the Enterprise have no effect. If any provision is unenforceable, the remainder stays in effect. Failure to enforce a provision is not a waiver.

19. Contact #

Questions about these Terms may be directed to Ubiqio Pte. Ltd., [email protected]

Acceptable Use Policy

Effective Date: July 2026

1. Purpose and Scope #

This Acceptable Use Policy (the “AUP”) governs the Enterprise’s and its Authorized Users’ use of the Ubiqio Platform and Unified API (the “Services”). It is incorporated into, and forms part of, the Ubiqio Terms of Service (the “Terms”). Capitalized terms not defined here have the meaning given in the Terms. Ubiqio may update this AUP from time to time in accordance with the Terms. Violation of this AUP is a material breach of the Terms and may result in throttling, suspension, or termination.

2. Layered Compliance — Ubiqio, CPaaS Providers, and Carriers #

Because Ubiqio routes Communications to the Enterprise’s chosen CPaaS Provider, the Enterprise must comply not only with this AUP but also with: (a) the acceptable-use and messaging policies of each CPaaS Provider it uses; (b) all applicable carrier, channel, and messaging-ecosystem requirements (including operator rules, sender-registration regimes such as 10DLC, and channel policies such as those of RCS and chat applications); and (c) all applicable laws. Where this AUP and a CPaaS Provider or carrier policy differ, the Enterprise must comply with the stricter requirement. Compliance with this AUP does not guarantee that a Communication will be accepted or delivered by a CPaaS Provider or carrier.

3. Consent and Recipient Rights #

• Obtain and maintain records of all consents, opt-ins, and authorizations required by law and by the applicable channel before sending any Communication.
• Provide clear identification of the sender and the purpose of the message, and, where required, clear opt-out or STOP instructions.
• Promptly honor opt-out, unsubscribe, and revocation requests, and refrain from further Communications to a recipient who has opted out.
• Do not contact numbers on an applicable do-not-call, do-not-disturb, or suppression list where prohibited.

4. Prohibited Content #

The Enterprise must not use the Services to transmit, request the transmission of, or process any content that:

• is unlawful, fraudulent, deceptive, misleading, or designed to impersonate another person or entity (including spoofing sender identity in violation of law or carrier rules);
• constitutes phishing, smishing, malware, ransomware, or other malicious code, or facilitates unauthorized access to systems or data;
• is defamatory, harassing, threatening, abusive, obscene, or that promotes violence, self-harm, or discrimination;
• is child sexual abuse material or otherwise sexually exploits or endangers minors;
• infringes any intellectual property, privacy, publicity, or other right of a third party; or
• relates to categories restricted or prohibited by applicable law, CPaaS Provider policy, or carrier rules (which may include, depending on jurisdiction and channel, content concerning sex, hate, alcohol, firearms, tobacco, cannabis, gambling, high-risk financial or lending offers, and certain regulated pharmaceuticals). The Enterprise is responsible for confirming the requirements applicable to its content and destinations.

5. Prohibited Conduct #

The Enterprise must not, and must not permit any third party to:

• send unlawful bulk or unsolicited Communications (spam), or engage in snowshoe or grey-route messaging or other traffic designed to evade filtering or carrier controls;
• use the Services in connection with any scam, fraud, deceptive marketing, or unlawful telemarketing;
• transmit Communications to or from emergency services (such as 911, 112, or equivalent), or represent that the Services can be used for emergency communications;
• use the Services in high-risk environments requiring fail-safe performance where failure could lead to death, personal injury, or severe physical or environmental damage;
• resell, sublicense, or provide the Services to a third party except as expressly permitted in an Order, or use the Services to build or benchmark a competing product;
• reverse engineer, decompile, or attempt to derive the source code or non-public logic of the Platform, except to the extent this restriction is prohibited by law; or
• collect, harvest, or process personal data through the Services without a lawful basis.

6. Security and Technical Use #

• Do not interfere with, disrupt, or compromise the integrity, security, or performance of the Platform or the networks or systems of Ubiqio, any CPaaS Provider, or any carrier.
• Do not attempt to gain unauthorized access to the Platform, other accounts, or related systems, or circumvent authentication, rate limits, quotas, or Message-Volume metering.
• Keep API keys and credentials secure; make only reasonable resource demands on the Platform in terms of request rate, payload size, and concurrency, consistent with the Documentation.
• Do not introduce viruses, worms, or other harmful code, or use automated means to abuse the Services.

7. Monitoring and Enforcement #

Ubiqio may, but is not obligated to, monitor use of the Services to verify compliance with this AUP and the Terms. Ubiqio may request evidence of the Enterprise’s compliance (such as consent records) and may investigate suspected violations. In response to an actual or suspected violation, a third-party or regulatory complaint, or a CPaaS Provider or carrier instruction, Ubiqio may throttle, filter, suspend, or terminate access to the Services, in whole or in part, with or without prior notice depending on the severity and the need to prevent harm, as further described in the Terms.

8. Reporting #

Suspected violations of this AUP may be reported to Ubiqio at [email protected]. Ubiqio may share information relating to suspected violations with affected CPaaS Providers, carriers, or authorities as reasonably necessary or as required by law.

Data Processing Addendum

Effective Date: July 2026

This Data Processing Addendum (“DPA”) forms part of the Ubiqio Terms of Service or other agreement between the Enterprise (“Controller”) and Ubiqio (“Processor”) (together, the “Agreement”) and applies to the Processing of Personal Data by Ubiqio on behalf of the Enterprise in connection with the Services. In the event of conflict between this DPA and the rest of the Agreement, this DPA governs with respect to the Processing of Personal Data.

1. Definitions #

“Data Protection Laws” means all laws and regulations applicable to the Processing of Personal Data under the Agreement, including, as applicable, the EU General Data Protection Regulation 2016/679 (“GDPR”), the UK GDPR and Data Protection Act 2018, the California Consumer Privacy Act as amended (“CCPA/CPRA”), and the Singapore Personal Data Protection Act (“PDPA”).

“Controller,” “Processor,” “Data Subject,” “Personal Data,” “Processing,” and “Personal Data Breach” have the meanings given in the applicable Data Protection Laws. Where the CCPA/CPRA applies, “Controller” includes “Business” and “Processor” includes “Service Provider.”

“Sub-processor” means a third party engaged by Ubiqio to Process Personal Data on Ubiqio’s behalf in order to provide the Services.

“CPaaS Provider” has the meaning given in the Terms.

2. Roles of the Parties #

The parties agree that, with respect to the Processing of Personal Data under the Agreement, the Enterprise is the Controller (or a processor acting on behalf of its own controller) and Ubiqio is the Processor acting on the Enterprise’s behalf. Ubiqio Processes Personal Data only to provide, maintain, secure, and support the Services and as otherwise permitted by this DPA.

3. Important — CPaaS Providers Are Not Ubiqio Sub-processors #

The Enterprise acknowledges and agrees that each CPaaS Provider it selects is engaged directly by the Enterprise and acts as the Enterprise’s own processor or as an independent controller in respect of the Communications delivered through that CPaaS Provider. A CPaaS Provider is not a Ubiqio Sub-processor. Ubiqio’s role is limited to routing the Enterprise’s Communications and associated Personal Data to the CPaaS Provider the Enterprise has chosen. The Enterprise is solely responsible for establishing an appropriate data processing agreement and lawful transfer mechanism directly with each CPaaS Provider, and Ubiqio is not responsible for the CPaaS Provider’s Processing of Personal Data. The Sub-processors for which Ubiqio is responsible under this DPA are limited to Ubiqio’s own infrastructure and service vendors listed in Annex III.

4. Processing Instructions #

Ubiqio will Process Personal Data only on the Enterprise’s documented instructions, including those set out in this DPA and the Agreement and as necessary to provide the Services, unless required to Process by applicable law (in which case Ubiqio will, where legally permitted, inform the Enterprise of that requirement). Ubiqio will inform the Enterprise if, in its opinion, an instruction infringes Data Protection Laws. The Enterprise is responsible for the lawfulness of the Personal Data it provides and of Ubiqio’s Processing on its instructions.

5. Confidentiality #

Ubiqio ensures that persons authorized to Process Personal Data are bound by appropriate confidentiality obligations and are Processing the Personal Data only as instructed.

6. Security #

Taking into account the state of the art, costs of implementation, and the nature, scope, context, and purposes of Processing, Ubiqio implements and maintains appropriate technical and organizational measures designed to protect Personal Data against a Personal Data Breach, as described in Annex II. The Enterprise is responsible for its own secure use of the Services, including safeguarding its credentials and configuring access appropriately.

7. Sub-processors #

The Enterprise provides a general authorization for Ubiqio to engage the Sub-processors listed in Annex III and to engage additional Sub-processors to provide the Services. Ubiqio will impose data-protection obligations on each Sub-processor that are substantially similar to those in this DPA, and remains responsible for its Sub-processors’ performance. Ubiqio will notify the Enterprise of intended changes to its Sub-processors (for example, by updating Annex III or a published list) and give the Enterprise a reasonable opportunity to object on reasonable data-protection grounds. For the avoidance of doubt, and as stated in Section 3, CPaaS Providers are not Ubiqio Sub-processors.

8. Assistance to the Enterprise #

• Ubiqio will, taking into account the nature of the Processing, provide reasonable assistance to the Enterprise (by appropriate technical and organizational measures, insofar as possible) to respond to requests from Data Subjects to exercise their rights.
• Ubiqio will provide reasonable assistance to the Enterprise with data protection impact assessments and prior consultations with supervisory authorities, taking into account the information available to Ubiqio.

9. Personal Data Breach Notification #

Ubiqio will notify the Enterprise without undue delay after becoming aware of a Personal Data Breach affecting Personal Data Processed by Ubiqio under the Agreement, and will provide information reasonably available to it to assist the Enterprise in meeting its own breach-notification obligations. Ubiqio’s notification is not an acknowledgement of fault or liability.

10. Deletion or Return #

On termination or expiry of the Agreement, Ubiqio will, at the Enterprise’s choice, delete or return the Personal Data it Processes on the Enterprise’s behalf and delete existing copies, except to the extent applicable law requires storage, and subject to the retention practices described in the Agreement and Ubiqio’s Documentation.

11. Audits #

Ubiqio will make available to the Enterprise information reasonably necessary to demonstrate compliance with this DPA and will allow for and contribute to audits, including inspections, conducted by the Enterprise or its mandated auditor, subject to reasonable notice, confidentiality obligations, frequency limits, and Ubiqio’s security and operational requirements. Ubiqio may satisfy audit requests by providing third-party certifications or audit reports where available.

12. International Transfers #

Where Ubiqio’s Processing involves a transfer of Personal Data from the EEA, the United Kingdom, Switzerland, or another jurisdiction with transfer restrictions to a country not recognized as providing an adequate level of protection, the parties will rely on an appropriate transfer mechanism, such as the European Commission’s Standard Contractual Clauses and the UK International Data Transfer Addendum, which are incorporated by reference and completed using the details in the Annexes.

13. CCPA/CPRA #

To the extent the CCPA/CPRA applies, Ubiqio acts as a Service Provider and will not sell or share Personal Data, will not retain, use, or disclose Personal Data except as necessary to provide the Services or as otherwise permitted by the CCPA/CPRA, and will not combine Personal Data with data from other sources except as permitted. Ubiqio certifies that it understands and will comply with these restrictions.

14. Liability #

Each party’s liability under or in connection with this DPA is subject to the exclusions and limitations of liability set out in the Agreement, including the liability cap in the Terms.

15. General #

This DPA is governed by the same law and dispute-resolution provisions as the Agreement, unless required otherwise by Data Protection Laws. If any provision is invalid, the remainder stays in effect. Except as amended by this DPA, the Agreement remains in full force.

Annex I — Details of Processing #

A. Parties. Data Exporter / Controller: the Enterprise, as identified in the Agreement. Data Importer / Processor: Ubiqio Pte. Ltd., provider of the Platform.

B. Subject matter and duration. Processing of Personal Data as necessary to provide the Services under the Agreement, for the duration of the Agreement and any period required to delete or return Personal Data.

C. Nature and purpose. Receiving, routing, orchestrating, temporarily storing, logging, and transmitting Communications and associated data through the Unified API to the Enterprise’s chosen CPaaS Provider; providing analytics, dashboards, and support.

D. Categories of Data Subjects. The Enterprise’s customers, end users, employees, contacts, and message recipients and senders.

E. Categories of Personal Data. Contact identifiers (such as phone numbers, email addresses, and messaging-app identifiers), message content and metadata submitted by the Enterprise, delivery and status information, and account and usage data of Authorized Users. The Enterprise controls the content it submits and should avoid sending special categories of Personal Data unless appropriate safeguards are in place.

F. Special categories. Not intended; the Enterprise is responsible for any special-category data it chooses to submit.

G. Frequency. Continuous, for the duration of the Agreement.

Annex II — Technical and Organizational Security Measures #

Ubiqio maintains a security program that includes, at a minimum, the following measures, which may be updated to reflect evolving practices provided protection is not materially diminished:

• Encryption of Personal Data in transit and, where appropriate, at rest.
• Access controls based on least privilege, with authentication and role-based authorization for personnel and systems.
• Network security, segregation, and monitoring, including logging of relevant events.
• Secure software development, change management, and vulnerability management practices.
• Regular backups and business-continuity and disaster-recovery measures appropriate to the Services.
• Personnel confidentiality obligations and security awareness training.
• Incident detection and response procedures, including breach notification as described in this DPA.
• Vendor risk management for Sub-processors.

Annex III — Approved Sub-processors #

Ubiqio engages the following categories of Sub-processors to provide the Services. (CPaaS Providers are not Sub-processors — see Section 3.)

• Cloud infrastructure and hosting: Amazon Web Services, Framer, Cloudflare
• Customer support and communications tooling: Google, Atlassian, Microsoft
• Billing and payment processing: Stripe

End of Ubiqio Legal Terms. Terms of Service · Acceptable Use Policy · Data Processing Addendum. Last updated July 2026