EU Data Act Addendum
This Addendum is incorporated into and made a part of the End User License Agreement
(EULA), and applies only where the Product falls within the scope of the EU Data Act.
1. Definitions
Exportable Data: Means Customer Data obtained and collected in connection with Customer’s
use of the Product or its Related Services, which Palo Alto Networks can lawfully retrieve
without disproportionate effort beyond a simple operation. Exportable Data excludes any
intellectual property or trade secrets of Palo Alto Networks or third parties and data whose
export would compromise product security or data inferred or derived from proprietary
algorithms. The Exportable Data, including details on the types and the format used to enable
portability, is listed in the EU Data Act White Paper on Palo Alto Networks’ Trust Center.
Switching: Means the process as defined under the Data Act, where a Customer transfers
Exportable Data to a different provider or to its own on-premises infrastructure.
Capitalized terms not otherwise defined herein shall have the meaning ascribed to them in the
EULA, or if not defined therein, the meaning provided under the EU Data Act.
2. Data Portability and Switching
a. Switching: Customer may initiate Switching by providing written notice to Palo Alto
Networks, observing a two-month notice period (“Transitional Period”), which can be extended
one time by the Customer by giving written notice to Palo Alto Networks. Palo Alto Networks
will provide reasonable assistance to the Customer and any authorized third parties to facilitate
the Switching process, which will be completed within 30 days. Throughout this period, Palo
Alto Networks will act with due care to maintain business continuity and ensure a high level of
security for the data being transferred. The Agreement will be considered terminated with respect
to the applicable Product and Related Service only upon completion of the Switching process or
upon expiration of the notice period where Customer does not wish to switch but to erase its
Exportable Data, and the Customer shall be notified of the termination.
b. Data Portability: The Customer may export eligible Exportable Data upon 30 days’ written
notice for 30 days after the termination of the Transitional Period (“Retrieval Period”). Except
for the Exportable Data that Palo Alto Networks is required to retain under applicable laws,
Exportable Data will be deleted upon the expiration of the Retrieval Period in accordance with
the applicable Privacy Datasheet(s). At Customer's request, Palo Alto Networks will provide an
executed copy of the certificate of destruction of Exportable Data to Customer. The Customer is
solely responsible for the import and implementation of Exportable Data into their new systems.
EU Data Act Addendum - September 2025
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