Data processing terms

Last updated: 26 October 2026. These terms form part of the agreement between [IOKO Labs Ltd] ("Snowleaf") and the Customer, and apply when Snowleaf processes personal data on the Customer's behalf through the Service.

1. Roles

1.1 For personal data in the Customer's account (for example names, work emails and roles of the Customer's users), the Customer is the data controller and Snowleaf is the data processor, under the Nigeria Data Protection Act 2023.

1.2 Energy readings and reports are mainly business data. Where they include personal data, these terms apply to it too.

2. What Snowleaf will do

Snowleaf will: (a) process personal data only on the Customer's documented instructions, which are the agreement and the Customer's use of the Service; (b) make sure everyone who processes it is bound by confidentiality; (c) apply the security measures listed in clause 5; (d) use sub-processors only as set out in clause 4; (e) help the Customer respond to data subjects exercising their rights, and with any data protection impact assessment, as far as reasonable; (f) notify the Customer without undue delay, and in any case within 48 hours, of becoming aware of a personal data breach affecting the Customer's data, so the Customer can meet the NDPA's 72-hour notification to the NDPC; (g) at the end of the agreement, delete or return the data as the Customer chooses, within 30 days, unless the law requires Snowleaf to keep it; (h) make available the information needed to show compliance with these terms, and allow reasonable audits [once a year, with 30 days' notice, at the Customer's cost].

3. Location and transfers

3.1 Data is hosted in Germany: the database with Neon (Frankfurt), the application on a Hetzner server, and uploaded files in Cloudflare R2’s EU region. Backups are kept in Germany with Neon. 3.2 Snowleaf will tell the Customer before changing the hosting country. Transfers outside Nigeria rely on [the NDPA basis the lawyer specifies]. 3.3 In-country hosting in Nigeria is available on request, at the price in the order form.

4. Sub-processors

4.1 Current sub-processors are the companies listed on our sub-processors page, each with what it does and the data it sees. Snowleaf uses no separate error-monitoring service. 4.2 Snowleaf will give 30 days' notice of a new sub-processor. The Customer may object on reasonable data protection grounds; if the parties can't resolve it, the Customer may end the affected service and receive a refund of prepaid fees for the remaining term.

5. Security measures

At minimum, before any Customer data is hosted: encryption in transit and at rest, including backups; row-level separation of each organisation's data in the database; least-privilege access for the application and staff; passwordless sign-in; upload limits and malware scanning; secrets kept out of source code; dependency vulnerability checks; restore-tested backups; logs that record actions but not file contents or credentials. The current status of each measure is published on the Snowleaf security page.

6. Duration

These terms last as long as Snowleaf processes personal data for the Customer.