Last updated: June 30, 2025

This Data Processing Addendum (“DPA”) is entered into by and between Tailscale and Customer and sets forth the parties’ obligations with respect to the Processing of Customer Data (definitions below). The effective date of this DPA shall be the same as that for the Agreement. For purposes of this DPA, the “Agreement” refers to either the Tailscale Terms of Service or the Main Service Agreement between you and Tailscale (as applicable to you). This DPA is incorporated by reference into the Agreement and constitutes the entire agreement between the parties on the subject matter hereof.

Definitions. Some capitalized terms are defined in this section, and others are defined contextually elsewhere in the DPA. Any capitalized terms not defined in this DPA have the meanings assigned to such terms in the Terms or MSA (as applicable to you). For purposes of this DPA, “Customer Data” means any data or information related to the configuration and management of Customer networks created using the Tailscale Solution (each network a “tailnet”) that are generated by or submitted to the Hosted Software by Customer, Permitted Users or Client Endpoints.

1.1 “Data Privacy Laws” means all applicable laws, regulations, and other legally binding requirements in any jurisdiction relating to privacy, data protection, data security, breach notification, or the Processing of Personal Data, including to the extent applicable the General Data Protection Regulation, Regulation (EU) 2016/679 (“GDPR”), the United Kingdom Data Protection Act of 2018 (“UK Privacy Act”), the Swiss Federal Act on Data Protection (“FADP”), the California Consumer Privacy Act, Cal. Civ. Code § 1798.100 et seq. and associated amendments and regulations thereto (“CCPA”) and similar U.S. state privacy laws, and the Canadian Personal Information Protection and Electronic Documents Act (“PIPEDA”). For the avoidance of doubt, if Tailscale’s Processing activities involving Personal Data are not within the scope of a given Data Privacy Law, such law is not applicable for purposes of this DPA.

1.2 “Data Subject” means an identified or identifiable natural person about whom Personal Data relates.

1.3 “EU SCCs” means the Standard Contractual Clauses issued pursuant to Commission Implementing Decision (EU) 2021/914 of 4 June 2021 on standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council.¹

1.4 “Personal Data” includes “personal data,” “personal information,” “personally identifiable information,” and similar terms, and such terms will have the same meaning as defined by applicable Data Privacy Laws, that is Processed in connection with the performance of the Services under your Agreement.

1.5 “Process” and “Processing” mean any operation or set of operations performed on data or on sets of data, whether or not by automated means, such as collection, recording, organization, creating, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

1.6 “Subprocessing” means any sub-contracted Processing that relates directly to the provision of the Services. This does not include ancillary services, such as telecommunication services, postal or transport services, maintenance and user support services or the disposal of data carriers, as well as other measures to ensure the confidentiality, availability, integrity and resilience of the hardware and software of data processing equipment. A “Subprocessor” is the person with which Tailscale has sub-contracted such Processing.

1.7 “UK SCCs” means the International Data Transfer Addendum to the EU Commission Standard Contractual Clauses, as published by the UK Information Commissioner’s Office and in force as of 21 March 2022. ²
Details of Processing.

2.1 Scope and Purposes. Tailscale will act as a “[sub]processor” or “service provider” (each as defined in and as applicable under applicable Data Privacy Laws) and will Process Customer Data in connection with the Services solely: to fulfill our obligations to you under the Agreement, including this DPA; on your behalf pursuant to your instructions; and in compliance with applicable Data Privacy Laws. The scope, nature, purposes, and duration of the Processing, the types of Customer Data Processed, and the Data Subjects concerned are set forth in this DPA, including without limitation Schedule C to this DPA. The details provided in Schedule C are deemed to satisfy any requirement to provide such details under any Data Privacy Law.

2.2 Restrictions. In compliance with Data Privacy Laws, Tailscale will not: (i) “sell” Personal Data (as such term in quotes is defined in applicable Data Privacy Laws); (ii) “share” or Process Personal Data for purposes of “cross-context behavioral advertising” or “targeted advertising” (as such terms in quotes are defined in applicable Data Privacy Laws); (iii) combine Personal Data with other personal information received from other sources as specifically prohibited under Data Privacy Laws; (iv) attempt to link, identify, or otherwise create a relationship between Personal Data and non-personal data or any other data without your express authorization; or (v) otherwise Process Personal Data for any purpose other than for the specific purposes set forth in the Agreement.

2.3 Acknowledgement. The parties acknowledge and agree that: (a) Tailscale is not a ‘Business Associate’ but rather a ‘mere conduit’ under HIPAA, Tailscale does not require any ‘personal health information’ to perform under the Agreement, and Customer Data will not include any ‘personal health information’; (b) Tailscale is not a ‘bank service provider’ as defined in the Bank Service Company Act; (c) Tailscale does not act as a ‘school official’ as defined under FERPA; and (d) Tailscale does not require any special categories of personal information as enumerated under GDPR Article 9(1) or other sensitive personal information (including any tax identification numbers, Social Security numbers, driver’s license numbers, or other similar government identification numbers) to perform under the Agreement, and Customer will not provide any such information in connection with the Services.
Requirements and Responsibilities.

3.1 Confidentiality. Tailscale will ensure that the persons we authorize to Process Customer Data are subject to a written confidentiality agreement or are under an appropriate statutory obligation of confidentiality.

3.2 Data Subject Requests. If Tailscale receives any requests from Data Subjects seeking to exercise any rights afforded to them under Data Privacy Laws regarding their Personal Data, to the extent legally permitted, we will promptly notify you or refer the Data Subjects to you for handling. Such requests related to Personal Data may include: access, rectification, restriction of processing, erasure (“right to be forgotten”), data portability, objection to the Processing, or to not be subject to automated individual decision making (each, a “Data Subject Request”). Tailscale will not respond to such Data Subject Requests itself, and you authorize Tailscale to redirect the Data Subject Request as necessary to you for handling. In the event you are unable to address a Data Subject Request through self-service capabilities, Tailscale will, upon your request, provide commercially reasonable efforts to assist you in responding to the Data Subject Request, to the extent we are legally permitted to do so and the response to such Data Subject Request is required under Data Privacy Laws.

3.3 Public Authority Requests.

3.3.1 To the extent legally permitted, Tailscale will notify you without undue delay if we receive a legally binding request for disclosure of or access to Customer Data from a public authority (including judicial or administrative authorities, or national security or intelligence agencies) or become aware of any direct access by a public authority to Customer Data. Such notification will include information about the Customer Data requested or accessed, the requesting or accessing authority, the legal basis for the request or access, and any response provided. If Tailscale is prohibited by applicable law or regulation from notifying you or disclosing the details of a public authority request to you, Tailscale will use its best efforts to obtain a waiver of the prohibition, with a view to communicating as much information as possible, as soon as possible.

3.3.2 Tailscale will use reasonably available legal mechanisms to challenge any binding legal requests for disclosure of or access to Customer Data made by a public authority that we receive, as well as any non-disclosure provisions attached to any such request. Tailscale will provide the minimum amount of information permissible when responding to a request for disclosure, based on a reasonable interpretation of the request.

3.3.3 To the extent legally permitted, and no more than once per calendar year unless otherwise required by Data Privacy Laws, Tailscale will, upon Customer’s written request, provide a report to Customer regarding binding legal requests for disclosure of or access to Customer Data we have received from public authorities (including with respect to national security requests), such report to include the number of requests, the type of Customer Data requested, the requesting authority(ies), whether the requests have been challenged, and the outcome of such challenges. Requests for such transparency reports should be sent to: privacy@tailscale.com.

3.4 Supervisory Authorities. To the extent legally permitted, each party will notify the other party without undue delay of any inspections or measures conducted by that party’s supervisory or regulatory authority, insofar as they relate to this DPA. Each party will cooperate with the supervisory authority of the other party to aid in their supervisory or regulatory authority’s performance of its tasks (insofar as they relate to this DPA) at the reasonable cost and expense of the party being inspected. In addition, at Customer’s reasonable cost and expense, Tailscale will provide Customer with reasonable cooperation and assistance for Customer’s consultation with regulatory authorities in relation to the Processing or proposed Processing of Customer Data, including complying with any obligation applicable to Tailscale under Data Privacy Laws to consult with a supervisory or regulatory authority in relation to Tailscale’s Processing or proposed Processing of Personal Data.

3.5 Complaint Handling. To the extent legally permitted, each party will inform Data Subjects of a contact point authorized to handle Data Subject complaints regarding the Processing of Personal Data under this DPA. Unless prohibited by applicable law, each party will promptly notify the other party of any complaints or claims regarding the Processing of Personal Data under this DPA. The parties will work together and provide reasonable cooperation and assistance to each other to promptly address any complaint or respond to the claim (as applicable).

3.6 Impact Assessments. Each party will provide reasonable assistance and cooperation to the other party for their performance of a data protection impact assessment or privacy impact assessment of Processing of Personal Data or proposed Processing activities of Personal Data, when required by applicable Data Privacy Laws.

3.7 Customer Responsibilities. Customer is responsible for the lawfulness of Personal Data Processing under or in connection with the Services. Customer will comply with all applicable Data Privacy Laws with respect to the collection and transfer of Personal Data to Tailscale and its Subprocessors, including providing any required notices to and obtaining all necessary consents, permissions and rights from Data Subjects under applicable Data Privacy Laws, for Tailscale to lawfully Process Personal Data for the purposes contemplated by the Agreement. Customer shall ensure that its Processing instructions to Tailscale comply with applicable law. Customer acknowledges that Tailscale has no obligation to assess the contents or accuracy of Customer Data, including to identify information subject to any specific legal, regulatory, or other requirement, and that Customer is responsible for making an independent determination as to whether the Services will meet Customer’s requirements and legal obligations under applicable law.

3.8 Tailscale Compliance. Tailscale certifies that it understands its obligations under this DPA and that it will comply with them. Tailscale will promptly and without undue delay notify Customer if it determines that either: (i) it can no longer meet its obligations under this DPA or applicable Data Privacy Laws; or (ii) in its opinion an instruction from Customer violates applicable Data Privacy Law; and will await Customer’s further instructions. Such notice will entitle Customer to terminate the Agreement (or, if applicable, only the affected Order Form(s)) and receive a prompt pro-rata refund of any prepaid amounts thereunder covering the remainder of the applicable term after the effective date of termination. This right to terminate and refund will be Customer’s sole and exclusive remedy with respect to the subject matter of this provision.

3.9 Good Faith Cooperation and Assistance. The parties understand and acknowledge that each party’s successful performance under this DPA will require the reasonable communication, cooperation and assistance of the other party. To that end, each party commits that it will operate in good faith and provide such reasonable cooperation and assistance.
Security Measures. We have adopted Security Measures regarding Customer Data as described in Schedule D. We will maintain such Security Measures to provide a level of protection that is appropriate to the risks concerning confidentiality, integrity, availability and resilience of the Services and Customer Data, while also taking into account the state of the art, implementation costs, the nature, scope and purposes of Processing, as well as the probability of occurrence and the severity of the risk to the rights and freedoms of Data Subjects.
Data Breaches. We will notify you without undue delay (and in any event within seventy-two (72) hours) of any known breach of security leading to the accidental, unauthorized or unlawful destruction, loss, alteration, disclosure of, or access to, Customer Data stored or otherwise Processed in connection with the Services (a “Data Breach”). We will also provide reasonable assistance to you in your compliance with your Data Breach-related obligations, including without limitation by: (a) taking steps to mitigate the effects of the Data Breach and reduce the risk to Data Subjects whose Personal Data was involved (such steps to be determined by Tailscale in our sole discretion); and (b) providing you with the following information, to the extent known: (i) the nature of the Data Breach, including, where possible, how the Data Breach occurred, the categories and approximate number of Data Subjects concerned, and the categories and approximate number of Customer Data records concerned; (ii) the likely consequences of the Data Breach; and (iii) the measures we have taken or propose to take to address the Data Breach, including where appropriate measures to mitigate its possible adverse effects. Where, and in so far as, it is not possible to provide all information at the same time, the initial notification will contain the information then available and further information will, as it becomes available, subsequently be provided without undue delay. For the avoidance of doubt, “Data Breach” does not include unsuccessful attempts or activities that do not result in the accidental, unauthorized or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Customer Data, including, but not limited to, unsuccessful log-in attempts, pings, port scans, denial of service attacks, and other network attacks on firewalls or networked systems. The parties agree that notice under this section is not an admission of fault or liability by the notifying party.
Subprocessors.

6.1 You acknowledge and agree that we may: (i) use our Affiliates and third party Subprocessors to Process Customer Data in accordance with this DPA and applicable Data Privacy Laws; and (ii) from time to time engage additional third parties for the purpose of providing the Services, including without limitation the Processing of Customer Data. Where we sub-contracts any of our rights or obligations concerning Customer Data, Tailscale will take steps to select and retain Subprocessors that are capable of maintaining appropriate privacy and security measures to protect Customer Data consistent with this DPA and applicable Data Privacy Laws, and enter into a written agreement with each Subprocessor to meet such obligations. We will remain liable for the acts and omissions of our Subprocessors as if they were our own.

6.2 You hereby consent to the use of the third party Subprocessors listed at tailscale.com/dpa-subprocessors or its successor webpages (the “Subprocessor Page”) as of the effective date of this DPA, and provide general written authorization to Tailscale to engage Subprocessors as necessary to provide the Services pursuant to the procedures set forth in this DPA. We will maintain the Subprocessor Page. The Subprocessor Page contains a mechanism to subscribe to notifications of updates to the Subprocessor Page; you will subscribe to receive notifications and updates via such mechanism.

6.3 We will provide notice and details of any changes to the Subprocessor Page via the subscription mechanism described in Section 6.2 or other electronic means. At least ten (10) days before enabling any new third party Subprocessor to access or participate in the Processing of Personal Data, we will update the Subprocessor Page and provide notice of the change. You may object to the new Subprocessor by informing us within ten (10) days of the notice date, provided such objection is in writing and based on reasonable grounds relating to data protection. You acknowledge that objecting to a Subprocessor may prevent us from offering the Services to you. If you do not object in writing within ten (10) days of notice, the Subprocessor will be deemed authorized for the purposes of this DPA. If you reasonably object and we do not respond to or resolve your objections within a commercially reasonable period of time, you will be entitled to terminate the Agreement with immediate effect by providing written notice to us. Upon such termination, Tailscale will refund to you on a pro rata basis any prepaid Fees covering the remainder of your Order Form or subscription term (as applicable) after the effective date of termination. Termination hereunder shall not relieve you of any Fees owed to Tailscale up to the date of termination. This right to terminate and refund will be your sole and exclusive remedy with respect to the subject matter of this provision.

6.4 If the parties have entered into Standard Contractual Clauses (“SCCs”) as described in Section 7 (International Data Transfers): (a) the above authorizations will constitute your prior written consent to our subcontracting of the Processing of Personal Data if such consent is required under the SCCs; and (b) solely upon your written request, we will make available to you copies of the agreements with authorized Subprocessors pursuant to Clause 9(c) of the SCCs, redacted as necessary to protect commercial information or other Tailscale Confidential Information unrelated to the SCCs.
International Data Transfers.

7.1 We will not engage in any cross-border Processing of Personal Data, or transmit, directly or indirectly, any Personal Data to any country outside of the country from which such Personal Data was collected, without complying with applicable Data Privacy Laws and the provisions in this Section 7. Where we engage in an onward transfer of Personal Data, we will ensure that, where legally required, a lawful data transfer mechanism is in place prior to transferring Personal Data from one country to another. You will ensure that you and your Permitted Users are entitled to transfer the Personal Data to Tailscale so that we may lawfully Process the Personal Data in accordance with this DPA, including without limitation by sub-contracting any Processing to an Affiliate or third party Subprocessor.

7.2 To the extent legally required, the EU SCCs form part of this DPA and will be deemed completed as set forth in Schedule A. In the event of a conflict between the terms of the EU SCCs and this DPA, the EU SCCs will prevail.

7.3 To the extent legally required, the UK SCCs form part of this DPA and will be deemed completed as set forth in Schedule B. In the event of a conflict between the terms of the UK SCCs and this DPA, the UK SCCs will prevail.

7.4 With respect to Personal Data transferred from Switzerland for which Swiss law (and not the law in any European Economic Area jurisdiction or the United Kingdom) governs the international nature of the transfer, references to the GDPR in Clause 4 of the EU SCCs are, to the extent legally required, amended to refer to the Swiss Federal Data Protection Act or its successor instead, and the concept of supervisory authority will include the Swiss Federal Data Protection and Information Commissioner. In the event of a conflict between the terms of the EU SCCs as amended by this Section 7.1.3 and this DPA, the EU SCCs as amended by this Section 7.1.3 will prevail.
Auditing Compliance. Upon your written request, and no more than once during each Order Form Term, we will provide you with our most recent security review reports and/or applicable certifications for the Services and provide reasonable assistance and information to you to understand the information in such reports. You agree that such third party reports and certifications are sufficient to demonstrate our compliance with the obligations set out in this DPA. If you have a reasonable objection that the information provided is not sufficient to demonstrate our compliance with this DPA, provided such objection is based on reasonable grounds related to data protection, you may conduct an audit, or select a mutually-agreed upon third-party to conduct an audit, of our practices related to compliance with this DPA, at your sole expense (an “Audit”). General DPA compliance Audits shall occur not more than once every twelve (12) calendar months. To the extent you use a third party representative to conduct the Audit (an “auditor”), you will ensure that your auditor is bound by obligations of confidentiality no less protective than those contained in this DPA and the Agreement. You will provide Tailscale with at least thirty (30) days prior written notice of its intention to conduct an Audit. Before any Audit, the parties will mutually agree upon the scope, timing, and duration of the Audit, as well as the Tailscale reimbursement rate for which you will be responsible. All reimbursement rates will be reasonable, taking into account the resources expended by us or on our behalf of Tailscale. You and your auditors will conduct Audits: (i) acting reasonably, in good faith, and in a proportional manner, taking into account the nature and complexity of the Services; and (ii) in a manner that will result in minimal disruption to Tailscale’s business operations and during Tailscale’s normal business hours. Neither you nor your auditors will be entitled to receive data or information of other Tailscale customers or any other Tailscale Confidential Information that is not directly relevant for the authorized purposes of the Audit in accordance with this provision. You will promptly provide us with the Audit results upon completion of the Audit. All Audit related materials will be considered “Confidential Information” subject to the confidentiality provisions of the Agreement.
Retention; Return or Destruction. We will retain Customer Data in accordance with its standard data retention policies and procedures (“Retention Procedures”). Upon your written request, we will make available to you those portions of our Retention Procedures, redacted as necessary to protect Tailscale Confidential Information, relevant to our Processing of Customer Data. Except to the extent required otherwise by applicable law, Tailscale will return or destroy Customer Data upon your request and within thirty (30) days of termination or expiration of the Agreement. Tailscale will provide you with a certificate of destruction only upon your written request. In case any applicable law prohibits the return or deletion of Customer Data, we warrant that we will continue to ensure compliance with this DPA and will only process the Customer Data to the extent and for as long as required under such law.
Updates to this DPA. We may need to update this DPA from time to time as laws, regulations and industry standards evolve, or as we make changes to our business or the Services. For example, if we release a new feature, product or service, we may need to update the information in the Schedules. If that happens, we will promptly post the revised DPA and update the “last updated” date. Unless otherwise specified by Tailscale, changes become effective for Customer: upon the next payment period (for Self-Serve customers); upon renewal of Customer’s then-current Order Term; or upon the effective date of a new Order Form; in each case as applicable to Customer and after the updated version goes into effect. Tailscale will use reasonable efforts to notify Customer of material changes through communications via Customer’s account, email or other means, and Customer may be required to click to accept or otherwise agree to the updated DPA. For the sake of clarity: updating this DPA to include a newly released feature, product or service does not by default constitute such a material change; and we will only make updates for features, products or services that are generally released (not for any that are in Research). Continued use of the Services after the updated DPA goes into effect as set forth herein will constitute Customer’s acceptance of such updated version.
Miscellaneous. Each party represents, warrants, and covenants that it understands and will comply with the restrictions and obligations set forth in this DPA. Each party further represents, warrants, and covenants that it will comply with all Data Privacy Laws applicable to such party in its role as data controller, business, data processor, service provider, or subprocessor (as applicable under Data Privacy Laws). If applicable to Customer, Customer represents and warrants that it is authorized to enter into this DPA, issue instructions, and make and receive any communications or notifications in relation to this DPA on behalf of Customer Affiliates. The parties acknowledge and agree that the exchange of Personal Data between the parties does not constitute a “sale” of Personal Data under any US Data Privacy Laws, and does not form part of any monetary or other valuable consideration exchange between the parties with respect to the Agreement or this DPA. Each party's liability arising out of or related to this DPA is subject to the “Limitations of Liability” section of the Agreement, and any reference in such section to the liability of a party means the aggregate liability of that party under the Agreement and this DPA together. The provisions of this DPA survive the termination or expiration of the Agreement for so long as Tailscale or its Subprocessors Process the Customer Data.

SCHEDULE A

EU SCCS - Modules Two or Three

By entering into this DPA and Schedule A, the parties are deemed to be signing the EU SCCs, including without limitation the applicable Annex Information set forth below. Any undefined capitalized terms used in this Schedule A have the meanings assigned to such terms in the EU SCCs.

Module Two or Module Three of the EU SCCs will apply as applicable to you.
The docking option under Clause 7 (Optional - Docking Clause) will apply.
This DPA and the Agreement are Customer’s complete and final instructions at the time of execution of the DPA for the Processing of Personal Data. Any additional or alternate instructions must be consistent with the terms of the DPA and the Agreement.
For purposes of Clause 8.1(a) (Instructions), the instructions will be deemed provided as set forth in Section 2 of the DPA, and include onward transfers to Subprocessors located outside the EU / EEA for the purpose of providing the Services.
For purposes of Clause 8.6(a) (Security of processing), Customer is solely responsible for making an independent determination as to whether the Security Measures set forth in Schedule D meet Customer’s requirements. By signing this DPA, Customer agrees that such measures provide a level of security appropriate to the risk with respect to its Personal Data.
For purposes of Clause 8.6(c), any personal data breach will be handled in accordance with Section 5 of the DPA.
The parties agree that the audits described in Clause 8.9 (Documentation and Compliance) will be carried out in accordance with Section 8 of the DPA.
For purposes of Clause 9(a) (Use of Subprocessors), Customer will be deemed to have given general written authorization in accordance with Section 6 of the DPA.
The parties agree that the certificate of deletion of Personal Data that is described in Clauses 8.5 (Duration of processing and erasure or return of data) and 16(d) (Non-compliance with the Clauses and termination) will be carried out in accordance with Section 9 of the DPA.
For purposes of Clause 15(1)(a) (Notification), Tailscale will notify Customer only and not the Data Subject(s) in case of requests from public authorities. Customer will be solely responsible for promptly notifying the Data Subject(s) as necessary.
For purposes of Clause 17 (Governing law), the parties choose Option 1 (the law of an EU Member State that allows for third-Party beneficiary rights) and agree that the EU SCCs will be governed by the laws of Ireland.
For purposes of Clause 18 (Choice of forum and jurisdiction), the parties agree that any dispute arising from the EU SCCs will be resolved by the courts in Ireland. A Data Subject may also bring legal proceedings against Customer and/or Tailscale before the courts of the Member State in which the Data Subject has their habitual residence. The parties agree to submit themselves to the jurisdiction of such courts.

Annex I(A): List of Parties

The Parties	Data Exporter	Data Importer
Name	Customer	Tailscale
Address	As provided in Customer’s customer account information	As provided in the Terms or MSA (as applicable to you)
Contact Person	As provided in Customer's Tailscale Customer account information	Helen Odom Director of Legal privacy@tailscale.com
Activities relevant to the transfer	Processing necessary to provide the Services to Customer and for any disclosures of Personal Data in accordance with the Agreement and the Tailscale Privacy Statement.
Role	Controller or Processor (as applicable)	Processor or Subprocessor (as applicable)

Annex I(B): Description of Processing & Transfer

As provided in Schedule C to this DPA.

Annex I(C): Competent Supervisory Authority

The competent supervisory authority will be in accordance with the provision applicable to Customer as provided in Clause 13(a) of the EU SCCs, and where possible, will be the Irish Data Protection Commissioner.

Annex II: Technical and Organizational Measures

As provided in Schedule D to this DPA.

Annex III: List of Subprocessors

Not applicable; Customer has given general written authorization in accordance with Section 6 of the DPA. Tailscale’s current list of Subprocessors as of the effective date, for which Customer grants general written authorization by signing this DPA, is available at the Subprocessor Page.

SCHEDULE B

UK SCCS

United Kingdom International Data Transfer Agreement

By entering into this DPA and Schedule B, the parties are deemed to be signing the UK SCCs, including without limitation the Mandatory Clauses in Part 2 and its applicable Tables and Appendix Information. The parties agree that this Schedule B appends Schedule A. Any undefined capitalized terms used in this Schedule B have the meanings assigned to such terms in the UK SCCs.

Table 1: List of Parties

Start Date	Coterminous with the Agreement	Coterminous with the Agreement
The Parties	Data Exporter	Data Importer
Full Legal Name	Customer’s full legal name	Tailscale’s full legal name
Trading Name (if different)	Customer’s trading name	Tailscale
Address	As provided in Customer’s Tailscale Customer account information	As provided in the Terms or MSA (as applicable to you)
Official Registration Number	As applicable to Customer	N/A
Key Contact	As provided in Customer’s Tailscale Customer account information	Helen Odom Director of Legal privacy@tailscale.com

Table 2: Selected SCCs, Modules and Selected Clauses

The “Approved EU SCCs” referenced in Table 2, to which this Addendum is appended, will be the EU SCCs as executed by the parties and completed as set forth in Schedule A.

Table 3: Appendix Information

As provided in Schedule A, with specific reference to Annex I(A), Annex I(B), Annex II, and Annex III.

Table 4: Ending this Addendum with the Approved Addendum Changes

Either party may end the UK SCCs as set out in Section 19 of the UK SCCs.

SCHEDULE C

Details of Processing

Categories of Data Subjects	Permitted Users
Categories of Data	Contact information (including name, email, role, company) Client device and node information (including IP address, unique device identifiers, operating system, software versions, user agent, host names, node public key, local network services, SSO authentication tokens, timestamps, connection attempts, connection outcomes, destination ports) Configuration information (including access control list information, webhooks, SCIM information) Customer Data resulting from your use of an Integration or other Third Party Service (as applicable)
Sensitive Data	Not applicable
Frequency of the Transfer	Continuous during the term of the Agreement
Nature & Purpose of Processing	Processing necessary to provide the Services to Customer and its Permitted Users. Processing necessary for any disclosures of Customer Data in accordance with the Agreement and Tailscale’sPrivacy Statement.
Purpose of Transfer	To provide the Tailscale Solution to Customer
Duration of Processing	The Processing commences upon Customer’s agreement to the Agreement and will terminate upon termination or expiration of the Agreement
Transfers to Subprocessors	Same as above with respect to the subject matter, nature and duration of the Processing

SCHEDULE D

SECURITY MEASURES

The following provides an overview of some key Security Measures with respect to Customer Data implemented by Tailscale. More information is available at tailscale.com/security/. The Services and security standards are subject to evolving risks, technical progress, and further development, and we reserve the right to implement alternative Security Measures or make future replacements or updates to our Security Measures as determined by us in our sole discretion.


Encryption	Control plane communication, which includes key exchange and coordinating device connections, employs a custom Noise IK-based protocol with X25519 as described in RFC7748. While it can operate directly over plain TCP in environments that allow it, it also supports being wrapped in TLS v.1.2 when necessary for compatibility or additional security requirements. Data resides at rest in the production environment encrypted with at least AES-256. For more information, see our Documentation on encryption available in the Knowledge Base here.
Standards Based Identity	We don’t want your passwords. We support Single Sign On (SSO) with multiple identity providers via SAML 2.0. We also offer customers the option to use their own identity provider (IdP). Any authentication settings from your identity provider are automatically used by Tailscale, including MFA and context-aware access. There are no “Tailscale usernames/passwords,” and we do not store or hash your IdP usernames/passwords as part of the Services.
Permission Management	Access Control Lists (ACLs) allow you to define what users, groups, IP addresses, CIDRs, hosts, and tags can connect to each other in your network. ACLs are directional and default deny. There are multiple user roles that restrict who can modify your tailnet’s configurations. These allow for separation of duties between admins who can modify users and devices, such as IT administrators, and those who can modify network configurations, such as the networking team.
Software development	The core functionality of the Tailscale Solution, including the coordination server, logging infrastructure, DERP relay servers, and clients, are written in Go. Go is a language that provides automatic memory management, and so doesn’t rely on the developer to allocate and free up memory — which prevents a whole class of memory safety vulnerabilities. All source code changes require a peer review and we regularly conduct audits of our source code. We have identity access management with SSO and MFA enabled for our production systems, and access permissions are reviewed quarterly.
Infrastructure	We use trusted third party cloud providers and leverage their tools to set up appropriate firewall rules, intrusion detection, and DMZ policies. Every component of our infrastructure has redundancy. We have an automated process that patches our virtual machines on a regular cadence. We have identity access management with SSO and MFA enabled for our production environment. We require a business need to access the production environment. We require connections over our own tailnet or using SSH keys to access the production environment. We perform real-time monitoring and proactive blocking of malicious user behavior. All actions on the back-end are logged and audited for unusual activity.
Continuous Security Assessments	We periodically use an independent third party to perform network penetration tests, application testing, and cloud assessments. Our SOC 2 report is available to Tailscale customers on the Tailscale website or upon request (subject to confidentiality).
Vendor Selection	All of our vendors offer industry-leading products and go through an exhaustive security review as a standard part of our vendor management policy, to ensure their practices meet our security and compliance standards.
Tailscale Personnel	Level of access is determined by role and based on principles of least privilege. Logical access reviews are performed periodically and access is immediately removed when no longer necessary. Multi-factor authentication is enforced for all personnel. Personnel devices have security features enabled, such as antivirus, disk encryption, automatic device blocking, and security patches. We run background checks and sign confidentiality agreements with personnel in accordance with applicable laws. We regularly provide security training for personnel.
Policies & Procedures	Among other company policies and plans, Tailscale has a Business Continuity Plan / Disaster Recovery policy that is routinely tested to maximize availability, and an incident response policy and plan.
Transparency	The source code for many of our key packages are publicly available in our open source repository, so your teams can directly review the code and confirm our security measures. We also publish security bulletins to disclose security issues in our product, and the security policies we use, so you can transparently see where we are in terms of security maturity.

Available at: https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32021D0914&from=EN. ↩
Available at: https://ico.org.uk/media/for-organisations/documents/4019539/international-data-transfer-addendum.pdf. ↩