Non-EU Data Transfer Policy

Last Updated on July 5, 2026

Welcome to Marketeq Digital Inc. (hereinafter referred to as "Marketeq," "we," "us," or "our"). This Non-EU Data Transfer Policy (the "Policy") describes how Marketeq handles the transfer of personal data across national borders, including transfers from the European Economic Area and other regulated jurisdictions to countries outside those jurisdictions. As a remote-first firm serving clients globally, Marketeq may transfer personal data internationally, and it applies appropriate safeguards when doing so. This Policy supplements our Privacy Policy and GDPR Compliance and Data Protection Statement and should be read together with them. If you have any questions about this Policy, you may contact us at legal@marketeqdigital.com.

1. Purpose and Scope

The purpose of this Policy is to explain how Marketeq protects personal data when it is transferred across borders. This Policy applies to transfers of personal data from jurisdictions that impose restrictions on international transfers, including the European Economic Area and the United Kingdom, to other countries. Because Marketeq operates globally, such transfers may occur in the ordinary course of providing its services. This Policy reflects our commitment to ensuring that personal data remains protected wherever it is processed. It should be understood in the context of our broader data protection framework.

2. When International Transfers Occur

International transfers of personal data may occur where Marketeq processes data using systems, personnel, or service providers located in different countries. Such transfers may arise, for example, where data is hosted on infrastructure located outside the originating jurisdiction, or where a processor supporting our services is located abroad. Because Marketeq draws on a global talent pool and works with clients worldwide, cross-border transfers are an inherent feature of our operations. We take steps to ensure that any such transfer is carried out in accordance with applicable law. We seek to limit international transfers to what is necessary for the relevant purpose.

3. Safeguards for Transfers

Where Marketeq transfers personal data from a jurisdiction that restricts international transfers to a country that does not provide an equivalent level of protection, we implement appropriate safeguards as required by applicable law. Such safeguards may include the use of standard contractual clauses approved by the relevant authorities, reliance on an adequacy decision where one exists, or other lawful transfer mechanisms. We select the appropriate safeguard based on the nature of the transfer and the parties involved. These safeguards are designed to ensure that transferred personal data continues to benefit from an appropriate level of protection. We keep our transfer mechanisms under review to ensure they remain valid and effective.

4. Transfer Impact Considerations

Where required, Marketeq assesses the circumstances of an international transfer to determine whether the chosen safeguard provides an appropriate level of protection in practice. This may include considering the laws and practices of the destination country and, where necessary, implementing supplementary measures to protect the data. We take a risk-based approach to such assessments, giving particular attention to sensitive data and higher-risk transfers. Where we determine that adequate protection cannot be ensured, we will reconsider the transfer. These considerations reflect our commitment to protecting personal data throughout the transfer process.

5. Onward Transfers

Where personal data transferred internationally may be subject to onward transfer by a recipient, Marketeq takes reasonable steps to ensure that such onward transfers are subject to appropriate safeguards. We require processors and other recipients to protect personal data consistently with our standards and applicable law, including in connection with any onward transfers. This helps to ensure that data remains protected throughout the chain of processing. We treat onward transfers as warranting the same care as the initial transfer. Our agreements with recipients address the conditions applicable to onward transfers.

6. Individual Rights and Information

Individuals whose personal data is transferred internationally by Marketeq retain the rights afforded to them under applicable data protection law. We provide information about our international transfer practices through this Policy and our Privacy Policy, and we make information about the relevant safeguards available upon request where required. Individuals may contact us to obtain further information about the transfer of their personal data or to exercise their rights. We handle such requests in accordance with applicable law. Transparency regarding international transfers supports individuals' ability to understand how their data is protected.

7. Security During Transfers

In addition to legal transfer mechanisms, Marketeq applies appropriate technical and organizational security measures to protect personal data during international transfers. Such measures may include encryption of data in transit and controls designed to prevent unauthorized access during transmission. These measures complement the legal safeguards described in this Policy. The security of data during transfer is treated as an integral part of our approach to international transfers. Our measures are designed to protect data against interception or compromise while it is being transferred.

8. Changes to This Policy

Marketeq reserves the right to modify or update this Non-EU Data Transfer Policy at any time to reflect changes in our practices or legal requirements, including developments in the law governing international transfers. Any changes will become effective upon posting the revised Policy, and we encourage you to review it periodically. Where changes are material, we will endeavor to provide additional notice through appropriate means.

9. Contact Information

If you have any questions, concerns, or requests regarding this Non-EU Data Transfer Policy, please contact us at legal@marketeqdigital.com. We are committed to protecting personal data wherever it is processed and to addressing your inquiries promptly and transparently.