Legal

Data Processing Agreement

Adminie Impact Technology Systems Uganda Limited · Last updated: 30 July 2026

This Data Processing Agreement (“Agreement” or “DPA”) forms part of the agreement between Adminie Impact Technology Systems Uganda Limited (“Adminie”, “Processor”) and the Customer using the Adminie platform (“Customer”), and governs the processing of Personal Data on behalf of the Customer through the platform.

In the event of any conflict between this DPA and the Privacy Policy with respect to Customer Data processed through the platform, this DPA shall prevail.

1 Definitions

For the purposes of this Agreement:

Controller — means the entity determining the purposes and means of the processing of Personal Data.
Processor — means Adminie, processing Personal Data on behalf of the Customer.
Personal Data — means information relating to an identified or identifiable natural person.
Processing — means any operation performed on Personal Data, whether by automated means or otherwise, including collection, storage, use, disclosure, alteration, or deletion.
Customer Data — means all information submitted to, or processed by, Adminie on the Customer’s behalf through the platform.
Applicable Data Protection Laws — means all privacy and data protection laws applicable to the processing of Personal Data under this Agreement.

2 Scope

This Agreement applies whenever the Customer uses the Adminie platform to process Personal Data relating to its employees, applicants, vendors, beneficiaries, donors, customers, researchers, students, or other individuals.

The Customer acts as the Controller. Adminie acts solely as the Processor.

3 Nature and Purpose of Processing

Adminie processes Personal Data only to:

Provide the Adminie software platform
Host Customer Data
Authenticate users
Provide technical support
Maintain security
Generate reports
Operate AI-powered capabilities requested by the Customer
Perform maintenance
Improve platform stability and performance
Comply with applicable legal obligations

Adminie shall not process Customer Data for its own marketing purposes. Adminie shall not sell Customer Data.

4 Processing Instructions

Adminie shall process Customer Data only to:

On documented instructions from the Customer
As necessary to provide the contracted services
Where required by applicable law

If applicable law requires processing beyond the Customer’s instructions, Adminie will notify the Customer unless legally prohibited.

5 Confidentiality

Adminie shall ensure that all employees, contractors, and authorized personnel with access to Personal Data:

Are subject to confidentiality obligations
Receive appropriate privacy and security training
Access Personal Data only where necessary

6 Security Measures

Adminie maintains appropriate technical and organizational safeguards, including where appropriate:

Encrypted communications using TLS
Encrypted storage where applicable
Role-based access controls
Authentication and password protections
Logging and monitoring
Regular security updates
Malware protection
Secure cloud infrastructure
Backup and disaster recovery procedures
Least-privilege access principles
Staff confidentiality obligations

Adminie may update these technical and organizational measures provided that security is not materially reduced.

7 AI Processing

Where the Customer enables AI-powered capabilities — Procurement Intelligence, Funding Prospecting, Hiring Support, or similar AI-driven functionality:

AI features process Customer Data only to provide the requested functionality
Customer Data is not used to market third-party products
Customer Data is not sold
Adminie implements reasonable safeguards to protect Customer Data processed by AI systems

The Customer remains responsible for determining whether AI-generated outputs are appropriate for its business decisions.

8 Customer Responsibilities

The Customer represents that it:

Has all necessary rights and legal bases for processing Personal Data
Has provided required notices to individuals
Will not upload unlawful content
Is responsible for the accuracy of Customer Data

9 Subprocessors

The Customer authorizes Adminie to engage subprocessors necessary for delivering the services. These may include providers of:

Cloud hosting
Analytics
Monitoring
Customer communications
Payment processing
Authentication
Infrastructure
AI services

Adminie shall impose appropriate data protection obligations on subprocessors and remain responsible for their performance under this Agreement. A current list of subprocessors is available on reasonable request to the Customer.

10 International Transfers

Customer Data may be processed in Uganda or other jurisdictions where Adminie or its service providers operate. Where international transfers occur, Adminie will implement appropriate safeguards required under applicable law.

11 Assistance to the Customer

Taking into account the nature of processing, Adminie will reasonably assist the Customer in responding to requests relating to:

Access
Correction
Deletion
Portability
Objection
Other rights available under applicable privacy laws

Where Adminie receives a request directly from an individual relating to Customer Data, Adminie will redirect the request to the Customer.

12 Security Incidents

Adminie shall notify the Customer without undue delay after becoming aware of a confirmed Personal Data Breach affecting Customer Data.

Such notification shall include details reasonably available, including:

Nature of the incident
Likely impact
Categories of affected data
Mitigation measures taken
Recommended next steps

13 Audits

Upon reasonable written request, and no more than once annually except where a confirmed security incident has occurred, Adminie will provide information reasonably necessary to demonstrate compliance with this Agreement.

Where appropriate, audits may be satisfied through independently issued security reports, certifications, or documentation.

14 Data Retention and Deletion

Upon termination of the services, Adminie shall, at the Customer’s choice and within a reasonable timeframe:

Return Customer Data
Securely delete Customer Data

unless retention is required by law. Backup copies remain until overwritten according to standard backup retention schedules.

15 Government Requests

Where legally permitted, Adminie shall promptly notify the Customer of legally binding requests from government or regulatory authorities for Customer Data.

16 Liability

Each party remains responsible for its own compliance with Applicable Data Protection Laws. Nothing in this Agreement limits either party’s liability where such limitation is not permitted by applicable law.

17 Term

This Agreement remains in effect for as long as Adminie processes Personal Data on behalf of the Customer.

18 Governing Law

Unless otherwise agreed in writing, this Agreement shall be governed by the laws applicable to the primary services agreement between the parties.

A Annex A — Processing Details

Subject Matter

Provision of the Adminie software platform.

Purpose

Delivery of software services, AI-powered features, support, hosting, security, and platform administration.

Duration

For the duration of the Customer’s use of the services, plus any legally required retention period.

B Annex B — Technical and Organizational Measures

Adminie maintains reasonable safeguards to include:

Access controls
Authentication mechanisms
Encryption in transit
Encryption where appropriate at rest
Network security controls
System monitoring
Security logging
Backup and recovery
Secure software development practices
Vulnerability management
Employee confidentiality obligations
Regular software updates
Principle of least privilege
Physical and environmental safeguards through trusted cloud infrastructure providers

19 Contact

For questions regarding this Data Processing Agreement, contact:

Adminie Impact Technology Systems Uganda Limited

Email: founders@adminie.com

Website: adminie.com

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