Data Processing Addendum
Last updated 5 October 2026
This Data Processing Addendum ("DPA") forms part of the Terms of Service (or other agreement) between Senverse Technologies Ltd ("Senverse") and the organization using Senport (the "Customer"). It applies to personal data that Senverse processes on the Customer’s behalf in providing Senport ("Customer Personal Data"). Capitalised terms not defined here have the meaning given in the Terms.
In short: you decide what personal data goes into Senport and why; we process it only to provide Senport to you, keep it secure and confidential, help you meet your obligations to the people it concerns, tell you promptly about breaches, and return or delete it when you leave.
1. Roles and scope
The Customer is the data controller of Customer Personal Data and Senverse is its data processor. Each party will comply with the data protection laws that apply to it, including the Data Protection Act, 2012 (Act 843) of Ghana and, where applicable, the laws of other countries in which the Customer operates (together, "Data Protection Law"). The subject matter, duration, nature and purpose of processing, and the types of personal data and data subjects, are described in Annex 1.
The Customer is responsible for the lawfulness of the processing it instructs, including having a lawful basis, providing notices to data subjects, obtaining any required consents, and the accuracy of the data it submits.
On-premise installations
Where the Customer runs Senport on infrastructure it controls (an "On-Premise Installation"), Customer Personal Data is stored and processed there, and Senverse does not host it or have access to it. In that case Senverse processes Customer Personal Data only when, and to the extent that, the Customer gives Senverse access to it (for example during a support session the Customer arranges), and this DPA applies to that processing. The sub-processors in Annex 3, the hosting location in section 7 and the Senverse security measures in Annex 2 apply to the Senport cloud service and not to an On-Premise Installation; the Customer is responsible for the hosting, security, backup and retention of its own installation.
An On-Premise Installation makes no connection to Senverse unless the Customer enables it. If the Customer enables the daily licence report, it contains only the licence, software version, number of seats in use and database version, and no Customer Personal Data. Any AI or messaging providers the Customer configures in an On-Premise Installation act for the Customer under the Customer’s own accounts and are not Senverse sub-processors.
2. Processing on instructions
Senverse processes Customer Personal Data only on the Customer’s documented instructions. The Terms, this DPA, the Customer’s configuration and use of Senport (including the features, integrations and retention settings its administrators enable) are the Customer’s complete instructions. Senverse will inform the Customer if, in its opinion, an instruction infringes Data Protection Law, and may process personal data otherwise only where required by law, after informing the Customer where legally permitted.
3. Confidentiality and personnel
Senverse ensures that its personnel authorised to process Customer Personal Data are bound by confidentiality obligations and receive appropriate training. Senverse staff do not access the content of the Customer’s records in the ordinary course. Where support requires it, access follows the support access process in section 4.
4. Support access
- A Senverse support person can view the Customer’s records only after one of the Customer’s administrators approves a request, or under a pre-authorisation the Customer has given for support cases it raised; the Customer is told of every visit and can end it at any time.
- Visits are read-only, limited to the areas approved, last at most two hours, end after 30 minutes of inactivity, and cannot impersonate a User.
- Every visit and action is recorded in the Customer’s audit trail and in Senverse’s own audit trail, and the Customer can download the record.
- Exporting data during a visit always requires a separate approval. Protected (whistleblowing) reports and sealed or restricted records are never accessible.
- Without a visit, Senverse staff see only operational information about the Customer’s organization, such as counts of activity and configuration status, and the name and email address of the organization’s owner.
5. Security
Senverse implements and maintains the technical and organisational measures described in Annex 2, which are designed to protect Customer Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. Senverse may update these measures provided it does not materially reduce the overall level of protection. The Customer is responsible for using the security features available to it, such as multi-factor authentication, single sign-on, IP restrictions and role permissions, and for protecting its Users’ credentials.
6. Sub-processors
The Customer authorises Senverse to engage the sub-processors listed in Annex 3. Senverse will impose on each sub-processor data protection obligations no less protective than those in this DPA, and remains responsible for their performance.
Senverse will notify the Customer of any new sub-processor at least 30 days before it begins processing Customer Personal Data, by updating Annex 3 and notifying the Customer’s administrators in Senport or by email. The Customer may object on reasonable data protection grounds within that period; the parties will discuss the objection in good faith, and if it cannot be resolved the Customer may terminate the affected service and receive a refund of prepaid fees for the remaining term.
Services that the Customer chooses and configures with its own accounts (listed in Annex 3) are not Senverse sub-processors; data the Customer sends to them is governed by its own arrangements with those providers.
Nor are the services Senverse uses only to protect its own sign-up page from automated and throwaway sign-ups (Cloudflare Turnstile, and public DNS and domain registration records). They process data about people registering a new organization, for which Senverse is the controller under its Privacy Policy, and never receive Customer Personal Data.
7. International transfers
Customer Personal Data in the Senport cloud service is hosted in Frankfurt, Germany (Amazon Web Services eu-central-1), and some sub-processors process data in other countries, as shown in Annex 3. Senverse will transfer Customer Personal Data outside Ghana only where the transfer complies with Data Protection Law, including by putting in place contractual commitments with recipients that require them to protect the data to the standard Data Protection Law requires. A Customer that needs data kept within a particular country can choose a dedicated installation, or an On-Premise Installation (section 1), under an Order Form; Senverse does not transfer the Customer Personal Data held in an On-Premise Installation.
8. Data subject requests
Senport gives the Customer tools to respond to requests from data subjects, including searching and exporting an individual’s data, recording and tracking requests against a deadline, correcting data, applying legal holds, redacting content, and erasing an individual’s identifying data. If Senverse receives a request directly from a data subject about Customer Personal Data, it will refer the request to the Customer and will not respond itself except to confirm the referral. Senverse will provide reasonable further assistance where the Customer cannot respond using these tools.
9. Personal data breaches
Senverse will notify the Customer without undue delay, and where feasible within 72 hours, after becoming aware of a personal data breach affecting Customer Personal Data. The notice will describe, as far as then known, the nature of the breach, the categories and approximate number of data subjects and records concerned, the likely consequences, and the measures taken or proposed. Senverse will provide further information as it becomes available, take reasonable steps to contain and remedy the breach, and cooperate with the Customer’s obligations to notify regulators and data subjects. Notifying a breach is not an admission of fault.
10. Assistance and records
Taking into account the nature of the processing and the information available to it, Senverse will provide reasonable assistance to the Customer with data protection impact assessments and prior consultations with regulators relating to Senport, and will maintain records of its processing activities as Data Protection Law requires.
11. Audits
Senverse will make available to the Customer, on request, the information reasonably necessary to demonstrate compliance with this DPA, such as descriptions of its security measures, policies and audit logs relating to the Customer. Where this is not sufficient, or where required by a regulator, the Customer may audit Senverse’s compliance, no more than once a year (unless following a breach or regulatory demand), on at least 30 days’ notice, during business hours, in a way that does not disrupt Senverse’s operations or compromise other customers’ data, and at the Customer’s cost. Auditors must be bound by confidentiality.
12. Return and deletion
- Return. The Customer’s administrators can export all of the Customer’s data at any time while the organization is active or read-only, in a complete, machine-readable format. After a subscription ends, the organization remains readable and exportable for 90 days before it is suspended (Terms, section 7).
- Deletion. When the Customer’s owner requests offboarding, the Customer has 30 days to cancel the request. After that, the organization is suspended and Senverse deletes the Customer’s data from the live Service and, on request, provides a certificate of deletion.
- What is retained. Senverse retains (a) the organization’s tamper-evident audit trail, as a record of activity, (b) billing and tax records as required by law, (c) data subject to a legal hold until the hold ends, and (d) copies in backups until they expire under Senverse’s backup schedule, during which they remain protected by this DPA and are not used except to restore the Service.
13. AI processing
Where the Customer’s administrators enable AI features, Senverse processes the relevant Customer Personal Data through the AI sub-processors in Annex 3 according to the data policy the Customer selects: blocking external AI, redacting personal data before external processing (the default), using a local model, or explicitly allowing unredacted processing. Senverse does not retain prompts or outputs beyond what is saved in the Customer’s records and does not use Customer Personal Data to train AI models.
14. Requests from authorities
If Senverse receives a request from a public authority for Customer Personal Data, it will, where legally permitted, refer the authority to the Customer and notify the Customer promptly, and will disclose only what it is legally compelled to disclose after assessing the lawfulness of the request.
15. Duration and liability
This DPA applies for as long as Senverse processes Customer Personal Data. Each party’s liability under this DPA is subject to the limitations in the Terms. If this DPA conflicts with the Terms on a matter of personal data, this DPA prevails.
Annex 1 — Details of processing
| Item | Description |
|---|---|
| Subject matter and duration | Provision of Senport for the duration of the Customer’s subscription and the periods set out in section 12 |
| Nature and purpose | Hosting, storage, retrieval, organisation, transmission (including through messaging, telephony and email channels), analysis (including optional AI assistance), backup, support and deletion, in order to provide Senport to the Customer |
| Data subjects | The Customer’s End Customers (including complainants, requesters, callers, reporters and their representatives); the Customer’s Users; other individuals mentioned in records |
| Types of personal data | Identification and contact details; identifiers such as national ID, Bank Verification Number and account numbers; date of birth and gender where collected; the content of tickets, complaints, cases, messages and attachments; call recordings and transcripts; USSD and survey input; payment and transaction details relating to complaints; location data where shared or recorded; User account, activity and audit data |
| Special categories | Only as the Customer chooses to collect, for example information about vulnerability, accessibility needs or health shared by End Customers. Senport lets the Customer restrict access to such records. |
| Frequency | Continuous, for the duration of the subscription |
Annex 2 — Technical and organisational measures
| Area | Measures |
|---|---|
| Encryption in transit | All public connections use HTTPS (TLS) with HTTP Strict Transport Security; webhooks Senport sends are signed (HMAC-SHA256 with replay protection) |
| Encryption at rest | Production database and backups stored on encrypted volumes and encrypted storage (AWS-managed encryption and AWS KMS); sensitive fields (national identifiers, tax identifiers, integration and payment credentials, single sign-on secrets, multi-factor secrets and protected reports) additionally encrypted in the application with AES-256-GCM using keys derived per organization and per field |
| Credentials and tokens | Passwords hashed with bcrypt; API keys, session tokens and recovery codes stored only as hashes; card numbers masked on intake |
| Tenant isolation | Each organization’s data separated by row-level security enforced by the PostgreSQL database for a database role that cannot bypass it; the application refuses to start if that role could bypass it; automated tests check every tenant table |
| Access control | Role-based permissions and Workspace scoping; multi-factor authentication (authenticator apps, passkeys and security keys); single sign-on (SAML, OpenID Connect, Google, Microsoft) on eligible plans; per-organization policies for required assurance level, IP ranges, idle timeout, concurrent sessions and password rules; email verification before sign-in; rate-limited authentication |
| Senverse personnel | Named accounts with multi-factor authentication for all staff access; least-privilege roles with periodic access reviews; customer-approved, read-only, time-limited support visits (section 4); emergency access audited and reviewed |
| Audit and integrity | Append-only audit trail protected by a cryptographic hash chain; audit records cannot be altered or deleted by the application |
| Application security | Content Security Policy and standard security headers; strict input validation; protection against server-side request forgery; signature verification for inbound channel webhooks; malware scanning of uploaded files, with files downloadable only after a clean scan; dependency and secret scanning |
| Resilience and backup | Continuous archiving of database changes and daily base backups copied off the server to encrypted storage in the same region; tested database restore procedures; incident management and published status updates |
| Data minimisation | Personal data redacted before external AI processing by default; error reports scrubbed of personal data; operational metrics about organizations limited to counts; protected reports stored without reporter identifiers |
| Customer controls | Data subject request tracking, export, correction, redaction, legal holds, retention schedules and erasure tools |
Annex 3 — Sub-processors
| Provider | Purpose | Data involved | Location | When involved |
|---|---|---|---|---|
| Amazon Web Services (AWS) | Hosting of the application, database, file storage and backups | All Customer Data | Germany (Frankfurt, eu-central-1) | Always |
| Resend | Sending notification emails; receiving emails sent to your inbound support address | Email addresses, names, message content and attachments | United States | Always |
| Africa’s Talking | SMS delivery, USSD sessions, voice calls and call recordings | Phone numbers, message content, USSD input, call audio | Kenya and the countries of its network partners | When SMS, USSD or voice channels are used |
| Hubtel; NALO Solutions | USSD short codes in Ghana | Phone numbers and USSD input | Ghana | When your organization uses these USSD providers |
| Anthropic | AI classification, sentiment, summaries and suggested replies | Ticket and conversation text (personal data redacted by default) | United States | When AI features are on |
| OpenAI | Text embeddings for finding similar tickets and knowledge articles | Ticket titles and descriptions | United States | When similarity features are on |
| Google Cloud | Speech-to-text transcription of calls, translation, and route planning for field visits | Call audio, text to be translated, visit coordinates | United States and other Google Cloud locations | When transcription, translation or route planning are used |
| Paystack | Processing subscription payments to Senverse | Billing contact name and email, payment amounts and references | Nigeria and Ghana | When paying for Senport by card or mobile money |
| Flutterwave | Processing subscription payments to Senverse | Billing contact name and email, payment amounts and references | Nigeria and the United States | When paying for Senport through Flutterwave |
| Sentry (Functional Software, Inc.) | Application error monitoring | Technical error data, with personal data removed before sending | European Union (Sentry EU region) | Always, once enabled |
Not sub-processors (section 6): Cloudflare Turnstile and public DNS and RDAP lookups, used only on Senverse’s own sign-up page.
Services configured by the Customer with its own accounts (not Senverse sub-processors):
- WhatsApp Business through Meta (WhatsApp Cloud API) or Twilio, and Telegram bots, using your own accounts;
- payment and mobile-money providers you connect for handling payment complaints and reversals (such as MTN Mobile Money, M-Pesa, Airtel Money, Paystack or Flutterwave under your own account);
- single sign-on identity providers (such as Google Workspace, Microsoft Entra ID, or any SAML or OpenID Connect provider);
- webhooks, API clients, data-warehouse exports and security (SIEM) feeds sent to destinations you choose;
- the Senport Connector, which links Senport to systems on your private network.