DRAFT for legal review. Placeholders in [brackets] must be completed and the text reviewed by a Nigerian lawyer before launch.

Data Processing Agreement

Version 2026-09-29

1. Parties and roles

This agreement is between you (the business, the data controller) and [Company Name Ltd] (RC [number]), [registered address] (the data processor), and forms part of the Terms of Service. It applies to personal data Reeplii processes on your behalf under the Nigeria Data Protection Act 2023 (NDPA) and its General Application and Implementation Directive.

2. What is processed

3. Our commitments as processor

4. Sub-processors

5. International transfers

Where sub-processors are outside Nigeria, transfers rely on the mechanisms allowed under Part VIII of the NDPA. [Lawyer to confirm and attach transfer clauses.]

6. Deletion and return

You can export your data at any time. When your account closes, we delete your customers' personal data within [30] days, except where the law requires us to keep it.

7. Audits

On reasonable notice, we will provide information needed to demonstrate compliance with this agreement.