WAWULegal

DATA PROCESSING AGREEMENT (DPA) FOR PARTNERS

Effective 26 October 2026

DATA PROCESSING AGREEMENT (DPA) FOR PARTNERS

This Data Processing Agreement ("DPA") applies where WAWU processes personal data on behalf of a Partner, or where a Partner processes personal data on behalf of WAWU.

1. DEFINITIONS

Terms used in this DPA have the meanings given in the Nigeria Data Protection Act 2023 (NDPA) and the UK GDPR where applicable.

2. ROLES

The Parties shall determine and document their respective roles as Data Controller and Data Processor for each processing activity.

3. PROCESSOR OBLIGATIONS

Where a Party acts as Data Processor, it shall process personal data only on the documented instructions of the Controller, implement appropriate technical and organizational security measures, assist the Controller in responding to data subject requests, notify the Controller of any personal data breach without undue delay, delete or return personal data at the end of the provision of services, and submit to audits and inspections as reasonably required.

4. CROSS-BORDER TRANSFERS

Any transfer of personal data outside Nigeria shall comply with Part VIII of the NDPA and Schedule 5 of the GAID.

5. LIABILITY

Each Party shall be liable for its own breaches of this DPA.

6. TERM

This DPA shall remain in effect for the duration of the partnership and shall survive termination to the extent necessary to comply with applicable law.