Data processing terms
Updated 2026-11-08
These terms form a data processing agreement between the client (controller) and Gahitwen (processor) under Tanzania’s Personal Data Protection Act, 2022.
They apply to personal data we process on the client’s behalf in the Niambie service.
Roles and scope
The client is the controller. Gahitwen is the processor. We process contact data, names, phone numbers, messages, templates and consent records to send and receive messages and run the service.
We will not process data for other purposes without the client’s instructions, except where the law requires it.
Instructions and confidentiality
We follow the client’s instructions in the service and in written communications. Our staff are bound by confidentiality and access data only for their work.
We will tell the client if an instruction appears to break the law, and we may pause processing until it is corrected.
Security
We use HTTPS, access control, two-step verification, AES-256-GCM encryption for Meta secrets, audit logs, backups and staff training.
We review risks and improve controls regularly. The client is also responsible for protecting its credentials and the data it puts into the service.
Subprocessors
Subprocessors are Meta (WhatsApp Business Platform), our hosting provider, our email provider, and an AI provider used for staff tools only.
We provide the list on request and will notify the client about material changes. The client may object to a new subprocessor on reasonable security grounds.
International transfers
We may transfer data outside Tanzania to Meta and other providers. We use contracts, security standards and the conditions of Tanzanian law to ensure appropriate protection.
Data subject rights
We help the client respond to requests to access, correct, delete, object to or port data, and to withdraw consent.
We pass requests to the client promptly and do not respond on the client’s behalf without instructions.
Data breach
We will notify the client without undue delay and within 72 hours of discovering a breach affecting its data, with details of the incident, impact and actions taken.
We will cooperate with the client in responding to authorities and data subjects where the law requires it.
Return and deletion
After the service ends, we return or delete data on the client’s instructions within 30 days, except billing, tax, audit records or data the law requires us to keep.
Backups are purged within 90 days. Opt-out records may be kept to prevent unwanted messages.
Audit and liability
On reasonable request and 30 days’ notice, the client may audit our security controls without breaching other clients’ confidentiality.
Each party’s liability under these terms is limited by the service terms, but not for confidentiality breaches or wilful misconduct.