Data Processing & Sub-Processors

1. The controller

Bodiop Ltd
TIN 155969694 · Registered in the Republic of Rwanda
Registered office: Kirehe, Eastern Province, Rwanda
NCSA-registered Data Controller 001/2376/0426, valid to 22 April 2029 — view certificate
Data protection contact: privacy@bodiop.rw · WhatsApp +250 729 909 068

Bodiop Ltd determines why and how subscriber personal data is processed, and remains accountable for it whichever provider holds it at a given moment.

2. Current sub-processors

This is the complete list as at the effective date above.

Providers previously listed and no longer used: Airtable (never brought into production), which never held Bodiop subscriber data.

3. What we require of every processor

We engage a processor only where it offers written data protection terms at least equivalent to the following. These are the commitments we rely on, and we do not claim rights we have not actually been granted.

1. Instruction only. Process personal data solely to deliver the contracted service on our documented instructions, and not for its own purposes — in particular not to train general-purpose models on our data, not to profile our subscribers, and not to sell or share the data.
2. Confidentiality. Bind every person with access to enforceable confidentiality obligations.
3. Security. Maintain appropriate technical and organisational measures — encryption in transit and at rest, access control, logging, tested backups and vulnerability management — proportionate to the risk.
4. Sub-processors. Engage further sub-processors only under terms no less protective than these, remain fully liable for them, and give us advance notice of changes with a right to object.
5. Assistance with your rights. Help us respond to access, rectification, erasure, restriction, objection and portability requests within the time the DPP Law allows, and pass any request received directly to us rather than acting on it.
6. Breach notification. Notify us without undue delay after becoming aware of a personal data breach, with enough detail for us to meet our own 48-hour obligation to the NCSA.
7. Deletion or return. Delete or return all personal data at the end of the service, except where law requires retention.
8. Transparency and audit. Make available the information needed to demonstrate compliance. For our larger providers this is satisfied by recognised independent audit reports and certifications rather than an on-site inspection, and we accept that. Where a provider is small enough for us to audit directly, we reserve that right on reasonable notice.
9. Transfers. Apply a lawful transfer mechanism for any processing outside Rwanda — see section 5.

4. What we commit to as controller

• Give each processor clear, documented and lawful instructions, and no more data than the service requires.
• Confirm a lawful basis exists before any personal data is transferred to a processor.
• Keep a record of processing activities and of the consents we hold.
• Assess a provider's data protection posture before engaging it, and review it if its terms change.
• Remain responsible to subscribers and to the NCSA for the lawfulness of all processing, including that carried out by processors on our behalf.
• Keep this page accurate and current.

5. Transfers outside Rwanda

Most of our processors operate outside Rwanda. For each transfer we rely on one or more of the mechanisms permitted under the DPP Law: contractual clauses imposing protection equivalent to Rwandan law, the processor's own certified transfer framework, and rigorous data minimisation.

Minimisation is the safeguard that does the most work. The processor located furthest away — the AI provider in China — receives no subscriber personal data at all in normal operation, because the AI reads opportunity listings rather than people. The full profile stays on our own server in Germany.

Where we cannot satisfy ourselves that a transfer is adequately protected, we do not make it.

6. Changes to this list

We update this page whenever a processor is added, replaced or removed, and we change the version number and effective date at the top.

Where a new processor would gain access to subscriber personal data, we notify subscribers by WhatsApp or email before it begins processing. If the change requires fresh consent, we ask for it rather than assume it.

To be told of changes to this list directly, email privacy@bodiop.rw with the subject "Sub-processor notifications".

7. Duration, termination and governing law

Each processing arrangement lasts as long as that processor provides its service to Bodiop Ltd, plus any period we are required to retain records. If a processor materially breaches its data protection obligations, we may terminate its service with immediate effect and move the processing elsewhere.

This page and the arrangements it describes are governed by the laws of the Republic of Rwanda, and any dispute falls to the competent courts of Kigali. Nothing here limits any right you have under the DPP Law or your ability to complain to the supervisory authority.