Payment Services Addendum

Last Updated: February 1st, 2026

URL: https://ordwaylabs.com/master-agreement/payments-services-addendum/

Recitals

This Payment Services Addendum (this “Addendum” or “PSA”) is incorporated into and forms a part of the Ordway Master Agreement (the “Master Agreement”), available at https://ordwaylabs.com/master-agreement/, between Ordway Labs, Inc. (“Platform,” “Company,” “we,” “us,” or “our”) and you, the customer (“Customer,” “User,” “you,” or “your”). By using the Payment Services described herein, you agree to be bound by this Addendum.

We provide payment processing, acquiring, and related services (the “Payment Services”) through our Platform System. To deliver the Payment Services, we utilize one or more third-party payment processors, acquirers, and service providers (each, a “Third-Party Partner,” and collectively, the “Third-Party Partners”). Our current Third-Party Partners include Adyen N.V. and/or its affiliates (“Adyen”). We may add, remove, or replace Third-Party Partners from time to time in our discretion. This Addendum sets forth the terms and conditions under which you may access and use the Payment Services through our platform and systems (the “Platform System”).

Order of Precedence.

In the event of a conflict between the terms of your Service Order, this PSA, and the Master Agreement, the following order of precedence shall apply: (1) the Service Order shall control over this PSA and the Master Agreement; and (2) in the event of a conflict between this PSA and the Master Agreement, this PSA shall control. In the event of a conflict between this Addendum and any Third-Party Partner Agreement (as defined below), the applicable Third-Party Partner Agreement shall control with respect to your obligations directly to such Third-Party Partner. Nothing in this Addendum shall be construed to diminish your obligations under any Third-Party Partner Agreement.

Article 1 – Payment Services; Onboarding

1.1  Acceptance of Third-Party Partner Terms.

As a condition of your access to and use of the Payment Services, you may be required to accept the terms and conditions of one or more Third-Party Partners. With respect to Adyen, you shall accept the general terms and conditions published by Adyen at https://www.adyen.com/legal/terms-and-conditions-adyen-for-platforms-2022 (or such successor URL as Adyen may designate), as amended from time to time (the “AfP Terms and Conditions”). Your acceptance of the AfP Terms and Conditions, together with your completion of the onboarding process, creates a separate agreement directly between you and Adyen (a “Third-Party Partner Agreement,” and with respect to Adyen specifically, the “User Agreement”). You may be required to enter into similar Third-Party Partner Agreements with other Third-Party Partners as a condition of using the Payment Services. You acknowledge and agree that:

• your use of the Payment Services is subject to this Addendum and any applicable Third-Party Partner Agreements;
• your eligibility for the Payment Services may be subject to the discretionary approval of the applicable Third-Party Partner(s), and neither we nor any Third-Party Partner guarantees that you will be approved;
• Third-Party Partners may amend their terms and conditions from time to time, and you shall accept such amendments as a condition of continued use of the Payment Services; and
• we shall provide you with copies of the then-current Third-Party Partner terms and conditions upon your request without undue delay.
• Payment Services are subject to the terms, rules, and requirements of applicable payment processors, card networks and associations, and financial institutions, including onboarding, underwriting, know-your-customer (KYC), anti-money laundering (AML), Payment Card Industry PCI-DSS (PCI-DSS), and National Automated Clearing House Association (NACHA) requirements. Customer agrees to comply with all such requirements as a condition of using Payment Services.

1.2  KYC and Onboarding.

You shall provide complete and accurate information as required by us and/or our Third-Party Partners in connection with the onboarding process, including all “Know Your Customer” documentation, business formation documents, beneficial ownership information, tax identification information, and any other information reasonably requested. You acknowledge that a Third-Party Partner may contact you directly for additional information. You shall:

• respond to any request for such information within thirty (30) days, and you acknowledge that failure to do so may result in your account being marked as inactive and the suspension of your Transaction processing;
• promptly notify us if any previously submitted information becomes inaccurate, incomplete, or out of date;
• certify that all information provided is true, accurate, and complete; and
• complete upfront verification as required by the applicable Third-Party Partner, which may include providing all required KYC documentation and undergoing identity and business verification before your first Transaction is processed (rather than on a deferred or threshold-based schedule).

1.3  Authorized Representative.

You hereby appoint us as your authorized representative with respect to your use of the Payment Services. Without limiting the generality of the foregoing, you authorize us to:

• access, use, and manage your data processed on the software, systems, and infrastructure operated by our Third-Party Partners (the “Payment Processing Systems”);
• configure and modify settings on the Payment Processing Systems on your behalf, including fraud control settings, payment method configurations, and account parameters;
• submit binding instructions to our Third-Party Partners on your behalf, including settlement instructions, payout triggers, and service activation or cancellation requests;
• request, activate, or cancel additional Payment Services or features on your behalf; and
• perform all other activities that we reasonably determine are necessary or appropriate in connection with your use of the Payment Services.

You shall provide us with all mandates, permissions, and instructions necessary for us to fulfill our obligations under this Addendum and our agreements with our Third-Party Partners. You acknowledge that our Third-Party Partners are entitled to rely on instructions and requests submitted by us on your behalf.

Article 2 – Settlement, Fees, and Payout

2.1  Fees.

You shall pay us the following fees in connection with your use of the Payment Services and the Platform System depending on the service selected in the Service Order:

(a) Processing Fees. The fees charged by us for your use of the Payment Services and the Platform System (the “Processing Fees”), as set forth in the fee schedule attached to your Service Order.

(b) Pass-Through Costs. All interchange fees, scheme fees, assessment fees, acquirer network fees, and any other fees, costs, or charges imposed by Scheme Owners, acquirers, issuing banks, Third-Party Partners, or other third parties in connection with the processing of your Transactions (collectively, “Pass-Through Costs”). Pass-Through Costs are charged to you at cost, without markup, and may vary from Transaction to Transaction based on card type, payment method, Transaction amount, and other factors determined by the applicable Scheme Owner or Third-Party Partner.  For clarity, where Customer is priced under Standard Pricing as specified in the Service Order, such Pass-Through Costs are included within the applicable Processing Fees, except for any separately itemized third-party fees expressly identified in the Service Order.

The Processing Fees and Pass-Through Costs are collectively referred to as the “Platform Fees.” “Transaction(s)” means the processing of any instruction for authorization, capture, and/or settlement of funds from your end customers (“Shoppers”) to you or us via the Payment Processing Systems. We reserve the right to modify the Processing Fees upon thirty (30) days’ prior written notice to you. Pass-Through Costs are subject to change at any time based on rates set by Scheme Owners, acquirers, and Third-Party Partners, and no advance notice from us is required for changes to Pass-Through Costs.

2.2  Authorization to Withhold Fees.

You hereby irrevocably authorize us to instruct our Third-Party Partners to withhold the Platform Fees (including both Processing Fees and Pass-Through Costs) from settled funds received from acquirers or payment network operators (each, a “Scheme Owner”) for your Transactions (“User Funds”) prior to settlement to you. You further authorize us to instruct our Third-Party Partners to withhold from User Funds any chargebacks (each, a “Chargeback”), refunds (“Refunds”), fines, penalties, or assessments imposed by a Scheme Owner, acquirer, or regulatory authority (“Fines”), and other amounts owed by you under this Addendum, the Master Agreement, or any Third-Party Partner Agreement.

2.3  Settlement of User Funds.

Our Third-Party Partners shall settle User Funds to your designated bank account after deducting the Platform Fees and any other amounts authorized to be withheld under Section 2.2. Settlement shall be made in accordance with the payout schedule we establish. You acknowledge and agree that:

• we shall submit binding settlement instructions to our Third-Party Partners on your behalf, and they are entitled to rely on such instructions;
• if User Funds remain in your account for more than thirty (30) days following settlement by the applicable Scheme Owner or acquirer, the applicable Third-Party Partner may pay out such funds directly to your designated bank account;
• settlement timing depends on the receipt of funds by our Third-Party Partners from third-party acquirers, Scheme Owners, and issuing banks, and neither we nor any Third-Party Partner shall be liable for delays in settlement caused by such third parties; and
• no payouts shall be made to you until all required onboarding and KYC information has been provided to and verified by the applicable Third-Party Partner.

2.4  Rolling Reserve.

You acknowledge and agree that our Third-Party Partners may withhold a portion of User Funds as a rolling reserve (the “Rolling Reserve”) to provide security for potential Chargebacks, Refunds, Fines, and other financial obligations you may owe. The Rolling Reserve is subject to the following terms:

(a) Reserve Level. The applicable Third-Party Partner shall determine the minimum Rolling Reserve amount required for your account (the “Reserve Level”) in its reasonable discretion, based on its then-current estimate of the uncompleted order amount, potential Fine exposure, and other potential liabilities attributable to your Transactions. The Third-Party Partner may adjust the Reserve Level from time to time. We will notify you of the applicable Reserve Level and any changes thereto.

(b) Condition to Settlement. Settlement of User Funds to you is conditioned upon your Rolling Reserve being at or above the applicable Reserve Level. The applicable Third-Party Partner will establish and maintain the Rolling Reserve at the Reserve Level by deducting funds from, or adding funds to, each settlement.

(c) Replenishment. If the Rolling Reserve falls below the Reserve Level at any time, the applicable Third-Party Partner may require you to immediately transfer sufficient funds to bring the Rolling Reserve back to the required level.

(d) Application of Rolling Reserve. The applicable Third-Party Partner may apply the Rolling Reserve, in whole or in part, to pay for Chargebacks, cover Fines, satisfy fraud claims, or pay unpaid fees owed by you.

(e) Release. Upon the earlier of (i) termination of the applicable Third-Party Partner Agreement, (ii) cessation of your Transaction processing, or (iii) the Third-Party Partner’s determination that a Rolling Reserve is no longer required, the Rolling Reserve will be released to you in monthly installments, net of any amounts applied to cover Chargebacks, Fines, fraud claims, or unpaid fees. As a standard matter, the Rolling Reserve will be fully released approximately six (6) months after processing of your Transactions has stopped, unless specifically identified potential liabilities remain at that time.

2.5  Settlement Delays and Probation Period.

You acknowledge and agree that your Transactions may be subject to a delayed settlement schedule as follows:

(a) Probation Period. For at least the first thirty (30) days following your first Transaction submitted through the Platform System (the “Probation Period”), User Funds may be settled on a delayed schedule as determined by the applicable Third-Party Partner. During the Probation Period, settlement delays may be longer than any standard settlement schedule that would otherwise apply.

(b) Ongoing Adjustments. After the Probation Period, the applicable Third-Party Partner may adjust your settlement delay at any time based on your (i) merchant category codes, (ii) risk profile, (iii) Refund and Chargeback rates, and (iv) any other relevant financial risk factors. Any settlement delay imposed may take precedence over any other settlement schedule, including Sales Day Payout, Accelerated Sales Day Payout, or similar arrangements.

(c) Extended Hold. Our Third-Party Partners reserve the right to extend your settlement delay up to one hundred eighty (180) days if your Transaction patterns indicate an elevated risk of Refunds, Chargebacks, or Fines, or if you cease or are expected to cease payment processing through the Platform System. We will notify you if such an extended hold is applied to your account.

(d) Legal Attachments. If we or a Third-Party Partner receive a third-party legal attachment or other legally binding order requiring either to withhold settlements and/or payouts, we and/or the Third-Party Partner will comply with such order, and neither we nor any Third-Party Partner shall have any liability to you as a result.

2.6  Notification of Settlement and Reserve Changes.

We will notify you of: (a) any changes to your settlement delay schedule; (b) the application, removal, or adjustment of your Rolling Reserve or Reserve Level; and (c) any material changes to the terms under which your Transactions are processed, in each case as communicated to us by the applicable Third-Party Partner. You acknowledge that such changes may be made by our Third-Party Partners in their discretion based on your risk profile and other factors, and that your continued use of the Payment Services following notice of such changes constitutes your acceptance thereof.

Article 3 – Chargebacks, Refunds, and Fees

3.1  Your Liability.

You shall be solely responsible for all Chargebacks, Refunds, and Fines attributable to your Transactions, regardless of whether such Chargebacks, Refunds, or Fines are initiated by a Shopper, issuing bank, Scheme Owner, acquirer, or regulatory authority. You hereby authorize us and our Third-Party Partners to fund Chargebacks and Refunds from User Funds in the first instance.

3.2  Negative Balances.

If Chargebacks, Refunds, Fines, or other deductions result in a negative balance in your account, you shall promptly reimburse us for the full amount of such negative balance. We may recover any negative balance by deducting amounts from future User Funds, invoicing you directly, or exercising any other remedy available under this Addendum or the Master Agreement.

3.3  Currency Conversion Adjustments.

Where a currency conversion has been applied to a Transaction and a Chargeback or Refund subsequently occurs, you shall be debited the original settlement amount you received in the original settlement currency. Any remaining difference between the original Transaction amount and the settlement amount (including currency conversion differences and related costs) shall be allocated as between you and us in accordance with the Master Agreement.

3.4  Cooperation with Investigations.

You shall cooperate fully and promptly with us and our Third-Party Partners in connection with any Chargeback dispute, fraud investigation, inquiry from a Scheme Owner, acquirer, or regulatory authority, or any audit or review of your activities. Such cooperation shall include providing records, documentation, and information within the timeframes requested by us, our Third-Party Partners, or the relevant third party.

3.5  Refunds Funded Solely from User Funds.

You acknowledge and agree that our Third-Party Partners are not obligated to execute a Refund unless the funds for such Refund can immediately be set off from User Funds available in your account. If User Funds are insufficient to cover a Refund, the Refund may be delayed until it is otherwise funded by you or us. Our Third-Party Partners will not fund Refunds from their own means. Available User Funds on your account may be used by our Third-Party Partners to execute Refunds to the relevant Shoppers before such funds are settled or paid out to you. All Refunds processed for your Transactions must use the same split configuration as the original Transaction, as further described in the applicable Third-Party Partner’s technical documentation.

3.6  Enhanced Chargeback Dispute Obligations.

In addition to the cooperation obligations set forth in Section 3.4, you shall use commercially reasonable efforts to avoid Chargebacks and Scheme Fines, including:

(a) actively disputing Chargebacks where you have a reasonable basis to do so;

(b) establishing and maintaining a Chargeback dispute flow procedure for the timely review and response to Chargebacks;

(c) cooperating with our requests and our Third-Party Partners’ requests (communicated through us) to review and improve your established dispute procedures; and

(d) connecting to and utilizing any chargeback dispute API or tools we or our Third-Party Partners make available for such purpose.

Article 4 – Compliance Obligations

4.1  Applicable Law and Scheme Rules.

You shall at all times comply with all applicable laws, statutes, regulations, and rules (“Applicable Law”) and the collective bylaws, rules, operating regulations, requirements, and procedures issued by the Scheme Owners applicable to the payment methods you enable and/or use (“Scheme Rules”). You shall not use the Payment Services for the benefit of any third party or resell access to any payment method unless expressly authorized under Applicable Law and Scheme Rules. Without limiting the foregoing, you shall not use or permit the use of the Payment Services in connection with:

(a) any product or service that violates Applicable Law or any applicable Scheme Rule;

(b) any product or service that appears on the prohibited or restricted products and services list maintained by the applicable Third-Party Partner (including Adyen’s list available at https://www.adyen.com/legal/list-restricted-prohibited, as amended from time to time), unless an express waiver has been obtained; or

(c) any Transaction under an incorrect or misleading merchant category code.

4.2  PCI DSS Compliance.

You shall maintain adequate security measures to ensure your compliance with the Payment Card Industry Data Security Standard (“PCI DSS”) and any other applicable data security standards required by Scheme Owners. You shall ensure the full security of Shopper payment card numbers, account numbers, security codes, and other sensitive payment information (“Payment Details”) as handled by you. You shall immediately notify us if you become aware of any actual or suspected breach of PCI DSS requirements or unauthorized access to Payment Details.

4.3  Anti-Fraud Obligations.

You shall immediately notify us if you have any reason to suspect fraud, illegal activity, or suspicious activity, whether reported by a Shopper or discovered by you through your own systems or processes. You shall maintain reasonable fraud prevention measures appropriate to your business and Transaction volume.

4.4  Prohibited Activities.

You shall not perform, or permit to be performed, any actions that are detrimental to the security or performance of the Payment Services or the Payment Processing Systems, including unauthorized access attempts, penetration testing without prior written consent, or any use of the Payment Services that violates Applicable Law regarding hacking and computer crimes.

4.5  Scheme Rule Violations and Fines.

You acknowledge that violations of Scheme Rules may result in significant Fines imposed by Scheme Owners, per-Transaction surcharges, and/or suspension or termination of your access to the applicable payment methods. You shall be solely responsible for, and shall fully indemnify us against, any Fines resulting from your non-compliance with Applicable Law or Scheme Rules.

4.6  Payment Facilitator Reporting.

Under Scheme Rules (including the rules of Visa, Mastercard, and other major card networks), a “Payment Facilitator” (sometimes called a “payfac”) is an entity that has entered into an agreement with an acquirer to facilitate payment processing on behalf of sub-merchants (referred to in this Addendum as “Customers” or “Users”) that do not have their own direct acquiring relationships. A platform qualifies as a Payment Facilitator when it (a) contracts with an acquirer (such as Adyen) to process payments, (b) onboards and underwrites sub-merchants to accept card payments through the platform, (c) aggregates sub-merchant transactions for submission to the acquirer, and (d) is registered with the applicable Scheme Owners as a Payment Facilitator. If we qualify as a Payment Facilitator, you shall cooperate with our reporting obligations to Scheme Owners, including by providing the following information upon request: your business identifier, DBA and legal name, URL, merchant category code, location, Transaction volume, and reason for termination (if applicable). You shall also cooperate with bi-annual PCI reporting requirements and any audits required by Scheme Owners.

4.7  Financial Information.

If there are clear indications that your financial risk has materially increased, you shall deliver to us, upon our request (which request may originate from a Third-Party Partner), any reasonably requested financial information within ten (10) business days of such request. Financial information may include, without limitation, financial statements, bank statements, cash flow projections, and other documentation reasonably necessary to assess your financial stability. You acknowledge that failure to provide such information within the required timeframe may result in a Third-Party Partner discontinuing certain risk management features applicable to your account, increasing your settlement delay, or adjusting your Rolling Reserve Level.

4.8  Processing Restrictions.

Your use of the Payment Services is subject to the following restrictions, which we may modify from time to time based on requirements from our Third-Party Partners:

(a) Approved Regions and Merchant Category Codes (MCCs). You may only process Transactions in the geographic regions and under the merchant category codes that have been approved by the applicable Third-Party Partner for your account. We will notify you of any applicable regional or MCC restrictions.

(b) Approved Payment Channels and Methods. You may only use the Payment Services to process Transactions using the payment channels (e.g., e-commerce, point of sale) and payment methods (e.g., card brands, ACH) that have been approved for your account. We reserve the right to restrict available payment channels and methods at any time based on Third-Party Partner requirements.

(c) No Internal Fund Transfers. You shall not instruct, request, or authorize any transfer of funds away from your account or between your account and the accounts of other Users through any internal funds transfer capabilities that may be available on the Platform System or the Payment Processing Systems, unless we provide prior written authorization for a specific transfer.

Article 5 – ACH Services

5.1  ACH Compliance.

To the extent you utilize ACH debit services through the Platform System (the “ACH Service”), you shall comply with all Applicable Law and Scheme Rules governing ACH transactions, including the NACHA Operating Rules, and shall complete and comply with any and all requirements and limitations set forth therein.

5.2  Company ID and Customer Authorization.

Prior to initiating any ACH debit entry, you shall provide the applicable Third-Party Partner’s Company ID to each customer that you wish to debit. You shall require each such customer to (a) notify its bank of such Company ID, and (b) authorize the applicable Third-Party Partner to debit the relevant bank account. We will provide you with the applicable Company ID. With respect to Adyen, the applicable Company ID is Adyen’s Company ID as provided to you by us.

5.3  Record Retention.

You shall obtain and retain, and provide to us upon request, records of all authorizations required under Applicable Law and Scheme Rules for ACH debit entries for a period of at least six (6) years, or such longer period as may be required by Applicable Law or Scheme Rules. You shall provide such records to us or the applicable Third-Party Partner upon written request.

5.4  Customer Notices.

You shall give prompt written notice to your customers of any (a) variable debit amounts, and (b) billing date changes, in the form and manner required by Applicable Law and Scheme Rules.

5.5  Suspension and Termination of ACH.

We may suspend or terminate your access to the ACH Service immediately if we or a Third-Party Partner know or have reason to suspect that you have breached Applicable Law or Scheme Rules. Upon any suspension or termination of the ACH Service, you shall cancel all outstanding authorizations for debit entries as of the date of such suspension or termination.

5.6  ACH PIN Security.

In accordance with the security requirements set forth in Applicable Law and Scheme Rules, you shall at all times remain responsible for the security of any debit entries, including secure PIN management.

Article 6 – Taxes, Tax Reporting, and 1099-K

6.1 Your Responsibility for Tax Withholding.

Our fees are exclusive of any applicable taxes, except as expressly stated to the contrary. You have sole responsibility and liability for: (i) determining what, if any, taxes apply to the sale of your products and services, acceptance of donations, or payments you make or receive in connection with your use of the Payments Services; and (ii) assessing, collecting, reporting, and remitting taxes for your business to the appropriate tax and revenue authorities. If we are required to withhold any taxes, or we are unable to validate any tax-related identification information you provide to us, we may deduct such taxes from amounts otherwise owed and pay them to the appropriate taxing authority.

6.2 Required Tax Information.

You shall provide us and our Third-Party Partners with all information necessary for the preparation and filing of IRS Forms 1099-K and any comparable state tax information returns, including your legal name, address, and taxpayer identification number (collectively, “Required Tax Information”). You certify that all Required Tax Information is and shall remain accurate and complete and shall promptly notify us of any changes thereto. You certify that all Required Tax Information provided to us or our Third-Party Partners is provided exactly as received from you, and you acknowledge that our Third-Party Partners may rely on such information without independent verification.

6.3  Consent to Electronic Delivery.

You hereby consent to the electronic delivery (“eDelivery”) of Forms 1099-K and related tax documents by or on behalf of us and our Third-Party Partners, in accordance with applicable IRS and state taxing authority guidelines. You further consent to the applicable Third-Party Partner’s role as the entity facilitating such eDelivery. You acknowledge the following:

(a) you may withdraw consent to eDelivery at any time by providing written notice to us, in which case paper copies of Forms 1099-K will be delivered to your last known address;

(b) we may change our method of eDelivery upon notice to you in accordance with IRS and applicable state guidelines; and

(c) to access Forms 1099-K electronically, you must have access to a computer or mobile device with internet connectivity and a current web browser or PDF reader.

6.4  Authorization to Share Tax Information.

You authorize us to share your Required Tax Information with our Third-Party Partners for the purpose of filing Forms 1099-K with the IRS and applicable state taxing authorities. You further authorize our Third-Party Partners to disclose and reconcile taxpayer identification information with the IRS and applicable state taxing authorities, and to perform backup withholding as required by applicable tax reporting requirements.

Article 7 – Payment Devices

7.1  Use of Payment Devices.

You shall use any hardware terminals or devices approved by the applicable Third-Party Partner for use in submitting point of sale Transactions (“Payment Devices”) solely in accordance with the approved technical requirements and usage instructions, as communicated to you by us from time to time. You shall not modify, tamper with, or alter any Payment Device.

7.2  Restrictions on Transfer.

You shall not resell, distribute, or otherwise make Payment Devices available to any third party. Payment Devices contain sensitive and proprietary data and may only be used in connection with the Payment Services.

7.3  Return of Payment Devices.

Upon termination of any applicable Third-Party Partner Agreement, this Addendum, or your cessation of use of Payment Devices, you shall promptly return all Payment Devices to us or the applicable Third-Party Partner in accordance with instructions we provide. Payment Devices must be returned for proper disposal in compliance with PCI DSS requirements.

Article 8 – Data Processing and Privacy

8.1  Data Processing.

You acknowledge and agree that in connection with the Payment Services:

(a) our Third-Party Partners may process personal data as processors acting on our instructions for certain payment processing activities, and as controllers for acquiring services, KYC/AML compliance, and other purposes described in their respective privacy statements;

(b) we and our Third-Party Partners will process your data and Shopper transaction data for the purposes of providing the Payment Services, fraud prevention, risk assessment, and data analytics;

(c) each Third-Party Partner’s privacy statement governs such Third-Party Partner’s processing of personal data in its capacity as a controller (with respect to Adyen, available at adyen.com); and

(d) our Third-Party Partners may comply with information requests from tax authorities and other governmental bodies in accordance with Applicable Law.

8.2  Your Obligations.

You shall ensure that you have obtained all necessary consents, authorizations, and legal bases required under Applicable Law (including applicable data protection laws) to transmit personal data of Shoppers and other individuals to us and our Third-Party Partners for processing in connection with the Payment Services. You shall provide any required privacy notices or disclosures to data subjects as required by Applicable Law.