Data Processing Agreement

Version 2026-10 · Last updated 18 October 2026

This agreement is between the business that creates an account on the Reborn Platform (the "Responsible Party") and Reborn Agency Pty Ltd (registration number 2026/739779/07), a private company registered in South Africa (the "Operator"). It applies from the moment the Responsible Party accepts the Terms of Use, and forms part of them. It is made under sections 20 and 21 of the Protection of Personal Information Act, 2013 ("POPIA").

1. What we process, and why

SubjectProviding the Reborn Platform to the Responsible Party.
Whose informationThe Responsible Party's customers, staff, website visitors and others who appear in the Responsible Party's records.
What kindNames, email addresses, phone numbers, request details, consent records and similar information that the Responsible Party or its visitors enter, and records of what the Responsible Party does in the Service.
How longFor as long as the account is active, then as set out in section 8.

2. Instructions

The Operator processes this information only on the Responsible Party's instructions, as given by using the Service, and does not use it for its own purposes. The Responsible Party is responsible for having a lawful reason to process the information and for telling people about it.

3. Confidentiality

The Operator treats the information as confidential. Only people who need access to run and support the Service can reach it, and they are bound by confidentiality.

4. Security

The Operator keeps the information secure with reasonable technical and organisational measures, including: encryption in transit; separation so each business sees only its own information (database row-level security); passwords stored only in scrambled form; access limited by role; one-way scrambling of visitor addresses used for abuse control; and monitoring of the Service.

5. Other providers (sub-operators)

The Responsible Party agrees that the Operator may use these providers to run the Service: Supabase (database and sign-in, London), Vercel (hosting, London) and Resend (email delivery, Ireland). If the Responsible Party switches on WhatsApp messaging, Meta will also process the messages. The Operator binds each provider to protect information to the standard this agreement requires, stays responsible for them, and will give notice of a new provider so the Responsible Party can object.

6. Transfers outside South Africa

Information is processed in the United Kingdom, Ireland and possibly the United States, by the providers above, under contracts that require adequate protection, as POPIA section 72 requires.

7. Helping with requests and incidents

8. When the agreement ends

When the Responsible Party's plan ends, the Operator keeps the information for at least 90 days so it can be downloaded, then deletes or de-identifies it unless the law requires it to be kept. The Responsible Party may ask for a copy or for earlier deletion at any time.

9. Checking compliance

On reasonable request, the Operator will give the Responsible Party the information needed to show that this agreement is being followed.

10. General

The limits on responsibility in the Terms of Use apply to this agreement. It is governed by the laws of the Republic of South Africa. Questions: info@rebornagency.co.za.

Reborn Agency Pty Ltd (registration number 2026/739779/07), a private company registered in South Africa. Contact: info@rebornagency.co.za